Sub-threshold firm notifications

Firms that are:

• small authorised UK AIFMs
• small registered UK AIFMs including EuSEF managers and EuVECA managers who may be both a small registered UK AIFM and/or a small authorised UK AIFM

are required to immediately notify us if the value of assets under management exceeds:

• €500 million in total in cases where the portfolio of AIFs consist of AIFs that are unleveraged and have no redemption rights exercisable during a period of five years following the date of initial investment of each AIF
• €100 million in total in other cases, including any asset acquired through the use of leverage

For the purpose of the thresholds, an AIFM may be the AIFM of an AIF whether it manages the AIF directly, or indirectly through a company with which the AIFM is linked by common management or control, or by a substantive direct or indirect holding.

AuM should be calculated in accordance with Article 2 of the AIFMD Commission Delegated Regulations [EU 231/2013].

Assessing a temporary versus permanent status

When assessing whether AuM exceeds the sub-threshold limit on a temporary or permanent basis, the AIFM should consider anticipated subscription and redemption activity or, where applicable, capital draw-downs and distribution. Anticipated market movements should not, however, be used as part of this assessment.

The AIFM should have regard to the extent to which the threshold has been exceeded and the frequency of any previous occurrences in the last year when determining whether the basis is likely to be of a permanent nature.

Permanent threshold status

In the case of a permanent status, during the interim period between submitting a variation of permission application for full-scope authorisation status and having the application determined by us, the AIFM is permitted to carry on managing its AIFs without restriction.

If, for whatever reason, the total value of assets under management falls below the relevant threshold during the interim period and before determination then we may consider requests to withdraw the application on a case by case basis.

How to submit a notification

Complete the notice of sub-threshold AIFM exceeding AUM limit form[1] and email it to [email protected].