The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement
Legal Framework
The offering of interests in a collective investment scheme (typically, LP interests) in
Japan and managing assets contributed by Japanese investors under such collective
investment scheme are regulated by Japanese law.
Principle:
Required to be registered in Japan as a financial instrument business operator
Exemption: Specifically Permitted Business for QIIs under Article 63 of the
FIEA (Article 63 Exemption)
File a notification under Article 63 of the FIEA
➤ Without registering as a financial instruments business operator, an Article 63 notification
allows a filer to
conduct private placements of interests in collective investment schemes, and
-
manage the assets under such collective investment schemes
with respect to QIIS and up to 49 general investors
Morgan Lewis
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