The AIFM Code will apply to AIFMs from the start of the first full performance period following AIFM authorisation and will primarily affect ‘AIFM Remuneration Code Staff’. These are staff whose activities have a material impact on the risk profile of the AIFM or the alternative investment funds (AIFs) it manages.
The guidance includes the finalized single AUM thresholds under stage one of the FCA’s proportionality assessment process. Firms yet to submit their application for AIFM authorisation will need to examine their AIFMs based on these thresholds and the additional proportionality factors in stage two. Firms already authorised or waiting for their application to be processed that have relied on the proportionality regime to disapply the more onerous requirements should review and test their documented disapplication rationale with their advisers in light of these finalized thresholds and further guidance.
The AIFM remuneration regime will not be fully applicable to many firms until 2015. Having now articulated their remuneration policies, these firms should now be finalising their compliance plans for operating under the new regime and (if relevant) be developing appropriate cash and instruments deferral structures capable of delivering variable remuneration to AIFM Code Staff in a regulatory compliant and tax efficient manner.
The final guidance also gives advice to firms still transitioning to the AIFMD remuneration regime on how best to fulfil the remuneration disclosure requirements for their AIF annual reports.
Full guidance
© FCA - Financial Conduct Authority
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