The reply claims that AIFMD is not tailored to VC funds. In particular, no lighter regime has been foreseen that could apply to small and medium VC managers, while granting them access to the passport for their funds under the AIFMD.
Increasing venture capital (VC) activities can be best achieved by designing a distinct regime for VC, which could be the topic of a separate piece of legislation. This approach would, in addition, give time to consult appropriately with various stakeholders without being caught by the AIFMD own deadlines.
ALFI/LPEA welcome a voluntary registration regime for managers of VC investment structures. This regime should benefit any entity managing third party funds or companies, as well as any internally-managed structures engaging in VC investments. To that effect, the concept of ‘internally-managed’ should also be recognised in the context of this regime.
ALFI/LPEA take the position that the requirements should be focused on the reputation and the experience of the persons who effectively conduct the business of the Manager. Managers would inform the competent authority of their home Member State (see item e) of the full document) on the structures under management. Managers willing to benefit from the fundraising passport should provide the competent authority with internal organisational information (e.g. rules on conflicts of interest), and, to a lesser extent, with financial-related information. In this regard, initial capital or own funds requirements should not be imported as such from Directives 2009/65/EC or 2011/61/EU, but rather be lowered.
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© ALFI - Association of the Luxembourg Fund Industry
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