Regulatory Alerts2014-11-06
Added · Updated
Requirements applicable to AIFMD managers performing investment services
AIFMD managers performing investment services must obtain explicit approval from the AFM and comply with CRD IV requirements, which take precedence where they are higher than AIFMD rules. Specific obligations include maintaining own funds of at least €125,000, adhering to the highest applicable solvency standards, and submitting both AIFMD and CRD IV reports. Consolidated supervision applies if the manager qualifies as an investment firm under CRD IV, and an Internal Capital Adequacy Assessment Process is required, while the obligation to obtain a declaration of no-objection for share acquisitions does not apply.
Q&A
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Question:
With which requirements must AIFMD managers comply if they also perform investment services?
Published: 06 November 2014
Answer:
Brief answer Subject to explicit approval by the AFM, an AIFMD manager may perform the following investment services: (1) managing individual assets, (2) giving advice and (3) receiving and transmitting orders. In addition, the AIFMD manager may perform the ancillary service of custody and administration of units in investment funds and UCITS. The AIFMD manager must however comply with the legal requirements pertaining to these services, i.e. it is subject to the same requirements as investment firms performing these activities. The requirements that apply depend on the nature of the activities that the institution performs rather than on its authorisation.
The following requirements apply to AIFMD managers performing investment services:
You can swipe the table to see more columns.
Topic
Requirement
Explanation
Own funds
At least €125,000
The highest of the CRD IV and AIFMD requirements apply.
Solvency
Highest of:
-
The AIFMD capital requirement or
-
The CRD IV capital requirement
The highest of the CRD IV and AIFMD requirements apply.
Consolidated supervision
Yes, insofar as relevant, based on CRD IV
Consolidated supervision does not apply to institutions qualifying as a firm under CRD IV.
Consolidated supervision applies to institutions qualifying as an investment firm under CRD IV.
Reporting
AIFMD reports as well as CRD IV reports
The reporting sets from both directives must be submitted
ICAAP
Yes
Performing individual as well as collective asset management may involve risks, which the institution must address in its ICAAP.
DNO required
No
The obligation to obtain a declaration of no-objection prior to acquiring a holding in an institution does not apply for investment funds (prior approval).
Remuneration policy
No
The AFM is responsible for supervision on remuneration policies of investment funds. The decision whether to impose CRD IV remuneration policy requirements on these institutions lies with the AFM.
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