What is the difference between a registered and a licensed small fund manager?
Both stay under the small fund manager thresholds. A registered small fund manager only registers its activity with the Financial Supervision Authority and is not supervised by it. A licensed small fund manager holds an activity licence and is supervised. The capital requirements also differ: 25,000 euros for a registered manager; 25,000 euros rising to 50,000 euros within three years for a licensed one.
When do I need a full AIFM authorisation?
When the assets under management exceed the small fund manager thresholds of 100 million euros (with leverage) or 500 million euros (unleveraged, no redemptions for five years), or when you need the rights of a fully authorised EU manager. We assess this before the work starts.
Is the capital included in your price?
No. The capital belongs to the fund manager and must be paid in by its owners. Our price is our professional fee for the work described.
Is the fund structure the same as the fund manager?
No. The fund structure (for example a limited partnership fund) is the vehicle in which investors invest. The manager is the company that manages it. We offer the corporate set-up of a fund structure separately on the licensed companies page.
What does a fund manager report to the Financial Supervision Authority?
An authorised AIFM reports regularly on the markets and instruments it trades, the exposures, risk profile, liquidity and leverage of the funds it manages (Article 24 of Directive 2011/61/EU); the frequency depends on the assets under management. Small managers have lighter obligations under the Investment Funds Act.
Who signs the supervisory reports?
The fund manager's management board signs and remains responsible for them. We prepare the reports from the data you supply and support the filing for twelve months; fund accounting, NAV calculation and the audit are not included.
Small AIFM or full AIFM — which do I need?
Below the AIFMD thresholds a manager can be registered as a small AIFM; above them, or to market to investors across the EU, a full authorisation is needed. We confirm this in the assessment.
What are the risks of a fund manager application?
Missing substance, a depositary not yet appointed, incomplete risk and liquidity policies or capital below the requirement.
Can the fund be managed remotely?
The manager must have real management in Estonia; delegation is possible within the AIFMD rules.