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

CP12/32
Implementation of the Alternative Investment Fund Managers Directive
Table 2: Costs to firms from authorisation requirements
Requirement One-off costs (per
AIFM)
Authorisation
(including new
permissions)
Variation of
permissions
Estimated number
of AIFMs in the
first year
Annex 1
X
Estimated total costs
(£m)
£11,000 – £127,000 20 – 40 £0.22 – £5.08
£0 – £270,000 450 – 1150 £0 – £314
Operating requirements
21. The Directive and its implementing measures include certain organisational requirements.
Most firms will not incur costs from these requirements or will only incur costs of minimal
significance, as they already comply. This is either due to existing FSA requirements for the
currently authorised firms or because the proposed requirements reflect current business
practice. Regardless, one respondent noted that AIFMD is likely to expand the role of the
compliance function, and this may also be the case in other areas. The cost estimates
provided by the respondents to our firm survey are summarised in Table 3.
22. Firms also noted that costs will depend on proportionality provisions, as for some firms it
would be disproportionate to the size and complexity of business to have separate functions.
One firm was concerned that if the risk management rules are not applied in a proportionate
way these could add up to £500,000 in costs annually. The respondents to the Deloitte survey
indicated that smaller firms were much more concerned about meeting the new requirements
than the larger firms. 7
7 See www.deloitte.com/assets/Dcom-UnitedKingdom/Local%20Assets/Documents/Industries/Financial%20Services/uk-fs-aifmd-surveyresponding-new-reality.pdf
A1:6 Financial Services Authority November 2012