Sub-threshold firm notifications

Find out how to notify us when a sub-threshold firm exceeds the assets under management (AuM) threshold.

    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].

    When to notify us you have exceeded the AuM threshold

    Notification of temporary status 

    You must notify us without delay from when the AuM was first identified as temporarily above the sub-threshold limit; the breach is deemed temporary if it is expected to last for three months or less.

    Verification of temporary status

    You must notify us exactly three months from when the AuM was first identified as being temporarily above the sub-threshold limit.

    Where an AIFM provides a satisfactory rationale for the situation being temporary it is not required to notify us at the point of resolution. Instead it need only validate this by providing the total assets under management figure at the point three months after the temporary situation was first identified.

    If, during the three month verification period, the AIFM identifies the circumstances have changed such that the status has altered from being temporary to permanent it should submit a notification of permanent status without delay and make preparations for submitting a variation of permission application and, subsequently, ensuring all necessary arrangements, systems and controls will be in place at the point that we determine the application.

    Notification of permanent status 

    Both the notification and the application for full-scope AIFM authorisation should be sent without delay but in any event no later than 30 calendar days from when the AuM was first identified as being permanently above the sub-threshold limit.

    Failure to comply with these timeframes may lead us to commence suspension or revocation of permission procedures against the AIFM.

    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 and email it to [email protected].