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ARTICLE · 14 OCTOBER 2013

What Should UK And Non EU AIFMs Be Doing Now?

Reed Smith (Worldwide)
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The AIFMD trigger date occurred on 22 July this year, with a 12-month transitional period (TP) in place in the UK for (i) existing UK managers of AIFs (UK AIFMs), and (ii) non-EU managers of AIFs (Non-EU AIFMs) actively marketed in the UK prior to the trigger date.

United KingdomFinance and Banking
Jacqui Hatfield
Jacqui Hatfield
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The AIFMD trigger date occurred on 22 July this year, with a 12-month transitional period (TP) in place in the UK for (i) existing UK managers of AIFs (UK AIFMs), and (ii) non-EU managers of AIFs (Non-EU AIFMs) actively marketed in the UK prior to the trigger date.

UK AIFMs The TP is currently in place for existing UK AIFMs, but those caught by the AIFMD should use this time to get ready for 22 July 2014. Amongst other things, a decision needs to be taken as to when the UK AIFM should apply for a variation of permission (VOP) to manage AIFs. The Financial Conduct Authority (FCA) wants applications from UK AIFMs to be submitted by January 2014. If a firm is not ready for full implementation of the AIFMD, or the passport is not required immediately, the VOP should make it clear that the variation is required to be effective on 22nd July 2014, because without this, technically the AIFMD will apply in full from the date the VOP is granted. The upside is that once the

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