Luxembourg Investment Vehicle Overview
Ok, I'll go for either a SIF or a SICAR:
What else should I know?
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AIFM
SIFS and SICARS are AIFs and either need to appoint an alternative investment fund manager
(AIFM) or can be self-managed internally. Chapter 15 or 16 ManCos or other companies can apply
for an AIFM licence (Super ManCo), which is granted by the CSSF.
Registration
Authorisation
The AIFM can obtain "registered" (so-called “de minimis") status if the SIF or SICAR's AuM remain
below €100 million when leverage is used or below €500 million when no leverage is used and
redemption is not possible for five years (the "thresholds").
Distribution
No EU Product Passport for public distribution in the EU is available for de minimis SIFS or SICARS!
... Not a problem! When there is no active distribution or you are only selling to a few investors,
you don't need to passport the fund: you can use the national private placement regimes (where
available).
Substance
If the thresholds are exceeded, the AIFM requires full substance under the AIFMD Law: this means
thorough organisation.
If the set-up costs for a fully licensed AIFM are too high, the SIF or SICAR can appoint an existing
fully licensed third-party AIFM.View entire presentation