The Central Bank of Ireland has opened a public consultation proposing significant enhancements to its non-UCITS regime in preparation for the implementation of the Alternative Investment Fund Managers Directive (AIFMD). The implementation of AIFMD will give rise to significant changes to the non-UCITS funds regime operated by the Central Bank. The Central Bank has therefore opened a consultation on these changes which include;

  • For retail investors in non-UCITS products, a separate Retail Investor Alternative Investment Fund (RIAIF) regime will be created.
  • The current Qualifying Investor Fund (QIF) regime will be replaced with a new Qualifying Investor Alternative Investment Fund (QIAIF) regime.

The new QIAIF regime will include some of the following changes:

  • Removal of the long-standing promoter regime (which includes the related promoter approval and capital requirements)
  • Removal of specific additional Prime Broker and Counterparty credit rating requirements
  • Provision for the fair as opposed to equal treatment of investors in different share classes
  • Provision for exclude and excuse share classes

In addition to the above changes, all existing non-UCITS Guidance Notes, Non-UCITS Notices and Policy Documents issued by the Central Bank of Ireland will be replaced by a new single handbook covering all aspects of regulation for AIFMs, QIAIFs, RIAIFs, Depositary and Administrator requirements. The consultation will close on December 11.