We at OWL are finding more and more clients seeking assistance with AIFMD implementation work. In a week’s time we should have the FSA’s final Consultation Paper – we should then know almost everything that is needed for full implementation.

There remains quite some uncertainty about when best to go for AIFMD permission. The earliest date for qualifying for the passports and complying with the Directive as a whole is 22nd July 2013. However, as is well known, the FSA has said that it will not entertain applications until that date, inevitably meaning that there will be some delay before permission is received. They may relent on that to facilitate earlier passports. We shall know very soon.

The last possible date for compliance is one year later – July 2014. Although most firms will instinctively wish to put off the evil day, it looks probable that many EU countries will make life difficult for those who do not wield the passport. Germany is even now unwinding its ‘private placement’ regime and others are expected to follow suit. That will mean that the passport will be the only way in. Sad to say, it looks as if life will not be easy for those without the AIFMD tag.