15.08.2013 Views

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

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

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

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

<strong>CP12</strong>/<strong>32</strong><br />

<strong>Implementation</strong> <strong>of</strong> <strong>the</strong> <strong>Alternative</strong> Investment Fund Managers Directive<br />

Costs<br />

Direct costs to <strong>the</strong> FSA and <strong>the</strong> FCA<br />

Annex 1<br />

X<br />

16. We estimate <strong>the</strong> one-<strong>of</strong>f costs <strong>of</strong> implementing <strong>the</strong> AIFMD to be around £5m. These cover<br />

staff costs and costs <strong>of</strong> anticipated systems developments following <strong>the</strong> high-level gap<br />

analysis on <strong>the</strong> back <strong>of</strong> <strong>the</strong> initial interpretation <strong>of</strong> <strong>the</strong> Directive.<br />

17. Additional supervisory staff may be needed on an ongoing basis due to <strong>the</strong> increase in <strong>the</strong><br />

number <strong>of</strong> regulated firms. However, most potential AIFMs are already authorised by <strong>the</strong> FSA,<br />

so we do not expect a significant number <strong>of</strong> new managers, ei<strong>the</strong>r start-ups or new entities<br />

consolidating previous businesses. In particular, investment managers <strong>of</strong> NURS, QIS, UCIS<br />

and externally managed investment trusts are already authorised and supervised by <strong>the</strong> FSA.<br />

Compliance costs to AIFMs<br />

18. Incremental compliance costs arising from <strong>the</strong> changes to parts <strong>of</strong> <strong>the</strong> Handbook are dealt<br />

with on a topic-by-topic basis in paragraphs 20 to 65.<br />

19. Table 1 gives an overview <strong>of</strong> <strong>the</strong> ranges <strong>of</strong> cost estimates provided by firms. 6 The fact that<br />

cost ranges are very wide reflects that <strong>the</strong> impact will vary greatly across <strong>the</strong> industry. In<br />

this and o<strong>the</strong>r cost summary tables, ‘£0’ covers cases where firms indicated that <strong>the</strong>y will<br />

not incur costs or where firms thought <strong>the</strong>se costs are likely to be <strong>of</strong> minimal significance.<br />

Also, not all costs were quantified in <strong>the</strong> CBA survey, and <strong>the</strong> effects <strong>of</strong> <strong>the</strong> following<br />

requirements are discussed only qualitatively:<br />

• securitisation requirements;<br />

• liquid asset requirements; and<br />

• requirements for depositaries.<br />

6 These estimates cover both staff costs and non-staff costs, such as costs <strong>of</strong> updating electronic systems. To quantify staff costs we<br />

assumed average annual salary <strong>of</strong> £50,000 plus 30% overheads.<br />

A1:4 Financial Services Authority November 2012

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!