The Irish Funds Industry Association has announced this afternoon
a hugely significant and extremely positive change in the authorization process
for Irish domiciled qualifying investor funds (ìQIFsî).
The QIF authorization process, as well as its product parameters,
are to be changed to accelerate the time to market and otherwise improve the
attractiveness of the QIF product.
QIFs will now be capable of being authorised by the Financial
Regulator on a filing only basis which will mean that there will no longer be a
prior review of QIF fund documentation and a QIF meeting the pre-agreed
parameters can file for authorization on Day X and authorization will issue on
New Irish Regulatory Regime
Following discussions over the last number of months between
industry representatives and the Financial Regulator, new authorisation
processes and enhanced product parameters for QIFs have been announced this
QIFs are non-UCITS products available as investment companies,
unit trusts or common contractual funds (single or umbrella with segregated
liability) which have a minimum subscription requirement per investor of Euro
250,000 (or equivalent) and which can be sold only to qualifying investors -
individuals with a minimum net worth of Euro 1.25 million (excluding principal
private residence/contents) or institutions who own or invest on a discretionary
basis at least Euro 25 million (or are themselves owned by qualifying
QIFs are the vehicles which are most frequently used in the
alternative space - hedge funds, fund of hedge funds, venture capital/private
equity, real estate funds etc - and are a mainstay of the non-UCITS Irish
domiciled product offering.
The new authorisation regime will provide that, subject to meeting
pre-agreed parameters, a QIF will now be capable of being authorised by the
Financial Regulator on a filing only basis so that once a complete application
for authorisation is received by the Financial Regulator before 3.00pm on Day
X, a letter of authorisation for the QIF can be issued by the Financial
Regulator on Day X +1.
There will no longer be a prior review process.
A complete application will be one where all the relevant parties
to the QIF (promoter, directors and relevant service providers) are all
approved (i.e. have the appropriate authorisations/approvals from the Financial
Regulator) and the QIF itself reflects the agreed parameters. The agreed
parameters have been...