Long Term Investment Funds – Review of EU rules

BKN Capital S.A. welcomes the opportunity to share its feedback on the EU Commission’s proposal for amendments to the ELTIF regulation. Overall we feel that the proposal is a big step in the right direction to realize the ELTIF regulation’s original objective to make private assets broadly accessible to the public in a regulated format.

Assogestioni welcomes the proposal of the Commission for the review of the ELTIF Regulation which, taking into account most of the considerations of the Association, identifies measures aimed at improving the attractiveness of ELTIFs by making them more flexible, in terms of investment policy and redemption policies, and more accessible to retail investors.

The International Securities Lending Association (ISLA) welcomes the opportunity to respond to this proposal. More information on ISLA and its members can be found here. ISLA would like to raise concern pertaining to the rules around eligible assets.

The changes included in the proposal for a revision of the ELTIF Regulation presented by the European Commission on 25 November 2021 go in the right direction overall. They are intended to improve the attractiveness of ELTIFs by making them, on the one hand, more flexible in terms of investment policy and redemption policies, with the expansion of investment activities and qualifying portfolio undertakings, and…

Filed in Italian · English published by the European Commission

ELTIFs have not yet reached their potential as a private financing vehicle. The Alternative Investment Management Association (AIMA), the Bundersverband Alternative Investments eV (BAI) and the Alternative Credit Council (ACC) (together ‘the Associations’) support the ambition shown in the proposed reforms of the ELTIF Regulation.

As an umbrella organisation of entrepreneurs and federations, the German Property Federation (ZIA) represents the interests of the property sector along its entire value chain, as well as all its types of uses. Among many others ZIA represents about 45 AIFM (“Kapitalverwaltungsgesellschaften”) that are managing open-end and closed-end real estate AIF.

Long-term investment funds – review of EU rules INREV is the European Association for Investors in Non-Listed Real Estate Vehicles. We provide guidance, research and information related to the development and harmonisation of professional standards, reporting guidelines and corporate governance within the non-listed property funds industry across Europe. INREV currently has approximately 480 members.

EFAMA strongly supports the Commission's draft proposal amending the ELTIF Regulation where it addresses some of the major obstacles that have undermined the attractiveness of the ELTIF product since inception. The revised legal framework has the potential to transform ELTIF into a product of choice for a larger (retail) investor audience, all while serving the purposes of the Capital Markets Union (CMU).

The reform of ELTIF Regulation plays an important role, given that ELTIFs didn’t spread as expected. We warmly welcomed the innovations set forth by the remarkable “Proposal for a regulation” and we bring to your attention some additional proposals. The current Regulation provides for a quite lengthy and complex authorisation process (i.e.

Dear Commission, in accepting the invitation referred to in the consultation paper on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/760 as regards the scope of eligible assets and investments, the portfolio composition and diversification requirements, the borrowing of cash and other fund rules and as regards requirements pertaining to the authorisation…

The European insurance industry welcomes the European Commission’s proposal to review the European Long-Term Investment Funds (ELTIF) Regulation. As the insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, improvements made to the ELTIF framework to make it more appealing to institutional investors are supported.

At the time, France Invest supported the creation of European long-term investment funds (ELTIFs): our members saw it as an opportunity to encourage investors to commit their capital for the long term. Indeed, private equity is a long-term investment: the average length of an investment into companies is around 6 years.

The reform of the Eltives would be a key element for the long term, in line with the Union’s objective of smart, sustainable and inclusive growth. However, the stated ambition seems ambitious and this project cannot replace the necessary revision of IFRS and Solvency II in favour of the long term.

Filed in French · English published by the European Commission

Commerzbank`s subsidiary CommerzReal has launched the ELTIF “KlimaVest” in 2021. The overarching goal in setting up an ELTIF as an impact fund investing in renewable energies investments for retail clients was to offer those investors the opportunity to benefit from attractive returns resulting from illiquid investments while making those investments redeemable on a daily basis by granting redemption rights.

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AMUNDI strongly supports the review of ELTIF aimed at increasing retail engagement in long term products. In line with the recommendations of the High Level Forum on Capital Markets Union. We believe that key areas to improve ELTIF are: i) enlarging eligible investments, (ii) easing the retail distribution challenges by removing quantitative thresholds to investments (iii) granting ELTIF tax neutrality.

BKN Capital S.A. is excited to be able to share its views on the ELTIF regulation and to provide formal feedback on the EU Commission’s “inception impact assessment”. Our feedback is attached hereto and has been structured around two of the three main areas of preliminary feedback received by the EU Commission to date from stakeholders: i. Removing limitations on the supply side ii.

BlackRock welcomes the recommendations of the High Level Forum on Capital Markets Union (HLF) on the ELTIF as well as the European Commission’s calls in the CMU Action Plan to promote the ELTIF. In addition to the HLF recommendations we note some additional, incremental changes which we believe will be beneficial. 1.

Review highlights three main areas: 1) Removing limitations on the supply side by improving the fund structuring and eligible assets related aspects of the ELTIF framework. We support this in principle – however, the specification of which assets can be invested should not be too much softened.

Triodos Bank advocates a revision of the ELTIF regulation which suits the Commission’s Just Transition ambitions. Leveraging public money with private money would enable thousands of projects and SMEs to contribute to a fair and green recovery. To that end, ELTIFs should be expanded to investments that suit the doughnut-criteria, considering social impact and environmental boundaries.

The BVI gladly takes the opportunity to contribute to the inception impact assessment by sharing its views on the current ELTIF regime considering the upcoming review of the Regulation. Please find our full response attached. The raison d'être of the ELTIF Regulation should be to address specific areas for which there are not yet sufficiently specialised fund products in the EU to achieve the desired objectives.

ELTIF Inception Impact Assessment – Feedback from the Alternative Credit Council The Alternative Credit Council (ACC), the global representative of the private credit industry, is pleased to contribute to the European Commission’s Inception Impact Assessment (IIA) of the ELTIF vehicle. The ACC has previously provided feedback in the enclosed position paper on ELTIF.

The European insurance industry supports the European Commission’s intention to make improvements to the European Long-Term Investment Funds Regulation (ELTIF) framework, as indicated in its Capital Markets Union (CMU) Action Plan (Action 3). The insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, for the benefit of its policyholders.

ELTIFs are investment vehicles geared towards long-term financing of the European economy and offer the advantage of being able to invest, in particular, in the capital of unlisted companies (including SMEs), in private debt or in real assets requiring significant initial investment, such as infrastructure.

FundRock Group is a leading independent UCITS Management Company and Alternative Investment Fund Manager (AIFM), offering solutions for Luxembourg, UK, Ireland and French-based funds with paid-up capital in excess of the €10 million capital requirement. Our strong foundations and long track record of offering substance through robust fund governance dates back to 1935 (RBS Trustee & Depositary Services).

The German insurance industry supports improvements to the ELTIF regulatory framework. The insurance industry needs access to a wide range of assets that generate stable revenues and match its long-term liabilities. Long-term investments in the real economy, as envisaged by ELTIFs, are generally of interest for insurers, particularly for portfolio diversification purposes.

Established nearly 40 years ago, France Invest brings together venture capital, private equity, infrastructure and private debt teams based in France, as well as the associated professions which support them. Its membership currently counts 340 management firms and 170 associate members.

Despite its laudable intention, the ELTIF label is only too rarely being adopted by AIF managers of “real assets”. Below we identify 5 key structural barriers that limit the use of ELTIFs and offer some suggestions for addressing such barriers – focusing on the real estate sector. 1.

Masaryk University welcomes the possibility to give feedback on ELTIF rules. Masaryk University, as an academic institution, considers the existence of ELTIF as very helpful for promoting innovation dissemination and "triple helix" (public, academic, private) cooperation.

It is important to define investment funds in their various forms, such as Fija, variable, variable, absolute returns. In addition to establishing public debt ceilings through loans incurred through investment funds or index funds for greater convenience.

Filed in Spanish · English published by the European Commission