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Very few ELTIFs were launched by professional investment managers since the Regulation became applicable in December 2015. Only around 28 ELTIFs have been established, with a low asset base (below 2 billion euros). From that perspective, the ELTIF Regulation has failed to meet its objective of boosting European long-term investments in the real economy.
However, EFAMA believes that the ELTIF regime – if properly adapted – can become a powerful tool to deliver on some of the Capital Markets Union’s (CMU) objectives and represent an attractive vehicle for investors in a low-for-long interest rate environment.
EFAMA recommends the following key changes to the current regime:
Turn ELTIF into an open-end structure alongside the existing closed-end one, by removing current limitations to its life cycle and by introducing appropriate redemption terms, and include adequate liquidity management tools.
Broaden the scope of the current eligible asset provision to include other types of funds, besides ELTIFs, EuVECAs and EuSEFs, as well as non-listed financial start-up companies.
Lower the current €10 million threshold for investments in “real assets”, thereby broadening choices for managers to consider smaller investment projects.
Remove quantitative limits (i.e., €500.000, 10% of the investable portfolio and a minimum of €10.000) and allow investments into ELTIFs as from €1.000 to reduce “supply-side” constraints.
Guarantee
the tax neutrality of the ELTIF structure to make it a
worthwhile investment tool.
Commenting
on the recommended changes, Federico Cupelli, senior regulatory
policy adviser at EFAMA, said: “Profound changes are necessary to make
ELTIFs an EU product of choice and help deliver on some of the
CMU’s objectives. These include promoting more participation in
less-liquid, real asset markets, as well as allowing both
institutions and individuals to invest a part of their wealth
over the long-term and diversify their exposure into private markets.
In this regard, we advocate a recalibration of the Regulation’s
asset eligibility requirements, minimum investment amounts and
adequate tax incentives”.
The full response can be found
here: 
EFAMA
ELTIF consultation response