Summary: The FCA is to be commended in producing comprehensive and pragmatic guidance, the effect of which will be both to delay the full impact of the code on UK AIFMs and to reduce its scope by applying the proportionality principles. There are many relatively smaller AIFMS who will benefit from this approach.
Meanwhile the opportunity to comment on the FCA guidance remains open until November 6, and, in particular, AIFMs are likely to have views on the FCA's suggested threshold for disapplying the pay-out process rules.
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