FCA updates submission process for marketing and material change notifications by AIFMs

What’s changing?

On 04 September 2019, the FCA updated its webpage on the National Private Placement Regime (NPPR), confirming that it will introduce changes to the submission of notifications by AIFMs marketing AIFs under the NPPR.

From Monday 09 September 2019, notifications must be submitted via the FCA’s online Connect system rather than on an NPPR notification spreadsheet.

Who does this change affect?

The change will apply to you if you are a full-scope UK AIFM intending to market an AIF under Article 36 of AIFMD which is:

• a third country AIF, or
• a UK or EEA feeder AIF where the master AIF is either
  • managed by a third country AIFM, or
  • a third country AIF.

It will also apply to:

• a Third Country (ie non-EU) above threshold AIFM intending to market an AIF into the UK under Article 42 of AIFMD, or
• a below threshold Third Country AIFM marketing an AIF into the UK.

However, full-scope EEA AIFMs intending to market AIFs into the UK under Article 36 of AIFMD will be required to submit notifications using new forms, rather than the Connect system.

Further details of the change will be published in due course on the FCA’s NPPR webpage.

If you require further information regarding the above, please get in touch with your usual Simmons & Simmons contact.