The FCA has updated its AIFMD webpage relating to authorisation applications from firms relying on the one year transitional period, which ends on 22 July 2014.
Whilst managers are not required to be authorised by 22 July 2014, they must submit a complete application by that date. The update reminds firms which defer their application until the end of the transitional period and therefore do not have the necessary authorisation on 22 July 2014 that they must be fully compliant with all relevant AIFMD requirements from this date, including, where necessary, engaging the services of a depositary.
The FCA also warns firms they may be at risk of business interruption if their application is materially incomplete or deficient and, as a result, authorisation cannot be granted. The FCA is strongly encouraging firms to submit a complete applications as soon as possible, and ideally no later than 22 April 2014.
The FCA update is a timely reminder that managers will need to appoint and on-board a depositary or depositary-lite provider by 22 July. We believe the FCA expects to see depositaries identified in authorisation applications for the submission to be deemed ‘complete’. As an Indos Financial update in this month’s Hedge Fund Journal highlights, managers need to allow sufficient time to on-board depositary-lite providers in a controlled manner and in order to ensure the manager gets the best commercial deal for the fund.
INDOS Financial was authorised by the FCA as a depositary-lite provider in early January, and remains the only authorised AIFMD depositary-lite firm in the UK. We are currently on-boarding a range of funds covering a broad spectrum of strategies and administrators. We would be delighted to talk to any managers seeking a pragmatic and cost-effective depositary-lite solution.
The FCA update can be viewed by clicking here.
To discuss how we can provide a depositary solution for your fund, please complete the form on the Contact Us page of our website.