Country Manual Independent Portfolio Manager/Advisor (EAM)
France out of EEA Update 2024
BRP has updated its Country Manual Independent Portfolio Manager/Advisor (EAM) for France out of EEA
| SOURCE OF CHANGES | ANSWERS |
| Law/Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | Yes |
Definitions & Concepts, Regulatory Overview and Behaviour Template
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.
Material changes
The main change/modification is as follows:
It is emphasized that the marketing of unregistered/passported AIFs by the fund’s own ManCo (or the delegated and duly notified marketer of the fund and the marketing of structured products by the issuer is only permitted within the framework of the (national) “private placement regime/exemptions”.
Non-material changes
The CM AM Regulatory Overview (CM AM RO) now includes information on National Private Placement Regimes (“NPPRs”) pursuant to art. 36 AIFMD which may permit the marketing of AIFs by EEA AIFMs to Professional Clients on a private placement basis.
In addition, some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
For more information, please contact us: info@brpsa.com
Best regards,
Geneva, July 22nd, 2024