CP12/32: Implementation of the Alternative ... - BVCA admin

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CP12/32 Implementation of the Alternative Investment Fund Managers Directive Question number 39 Should the capital requirements for depositaries within the third bullet of paragraph 7.3 of this DP be increased and, if so, what approach should be taken? What role could insurance have in supplementing this requirement? Where the depositary is within a group, to what extent would a parent stand behind its subsidiary in the case of a default and/or loss of assets? 40 Are there any bodies (e.g. lawyers, accountants or fund administrators) that intend to offer depositary services to the type of AIF in paragraph 7.7 of this DP? What would be an appropriate prudential regime for these types of depositary and what level of financial or professional guarantees should be given? Should we apply any other FSA requirements to these depositaries? 45 Do you consider that those entities performing the primary depositary functions should be acting independently of the AIFM and not be part of the same group as the AIFM? What are the implications of such an interpretation? 46 What is the appropriate regulatory treatment for firms that carry on one or more of the three primary depositary functions for non-EU AIFs? Are there industry codes or principles of best practice that these firms should adhere to? Annex 7X Chapter where we make proposals Chapter 9 Chapter 9 Chapter 9 Chapter 9 A7:2 Financial Services Authority November 2012
Appendix 1 CP12/32 Implementation of the Alternative Investment Fund Managers Directive Draft Handbook text
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Consultation Paper CP12/32 Financia
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The Financial Services Authority in
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CP12/32 Implementation of the Alter
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Page 72 and 73: CP12/32 Implementation of the Alter
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Page 124 and 125: ALTERNATIVE INVESTMENT FUND MANAGER
Page 126 and 127: Annex A Making the Investment Funds
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Page 130 and 131: 3.2.5 R An AIFM must, for each AIF
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Page 152 and 153: instruments remain in its custody;
Page 154 and 155: supplementing this section] 4. Comm
Page 156 and 157: Annex B Amendments to the Glossary
Page 158 and 159: collective portfolio management fir
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Page 162 and 163: BIPRU 730k firm Page 39 of 91 Appen
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Page 166 and 167: esources only at excessive cost. Pa
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Page 49 of 91 Appendix 1 7.1.7B In
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[Note: paragraph 1(c) of Annex II o
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[Note: paragraph 1(k) of Annex II o
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[Note: paragraph 1(r) of Annex II o
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Page 61 of 91 Appendix 1 amount of
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Types of investment firm: BIPRU 50K
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The following text is new and is no
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Page 67 of 91 Appendix 1 (1) at the
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Page 69 of 91 Appendix 1 so that th
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TABLE 7.4 PART I A firm must calcul
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Note consistently in respect of any
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initial capital (see item 5) if the
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Form of qualifying subordinated loa
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Annex H Amendments to the Supervisi
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Descriptio n of data item Annual re
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… Data item SUP 16.12.12R, unless
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indicated otherwise. Data item Firm
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client assets … Page 87 of 91 App
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… Data item SUP 16.12.23R, unless
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FSA066 and FSA06 are added - see fo
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Liquid assets test 32 Liquid assets
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Professional negligence capital req
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is not listed, select ‘Other’.
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FSA067 Capital adequacy - supplemen
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PII capital requirement 5A This is
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External validations Validation Dat
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