Small Registered AIFM

Under the UK AIFM regime, Managing an AIF is a regulated activity that covers the risk and portfolio management of alternative investment funds (AIFs), which is reflected as two Part 4A FCA permission variants based on the authorisation status of the fund being managed: Managing an Authorised AIF and Managing an Unauthorised AIF.^[2]
A small registered UK AIFM is a sub-threshold AIFM that falls within the AIFMD “small AIFM” limits and is registered with the FCA under the Small Registered Regime, rather than being authorised as a full-scope UK AIFM or small authorised UK AIFM.^[3] Full-scope and small authorised UK AIFMs are authorised by the FCA to manage AIFs, whereas small registered UK AIFMs manage eligible AIFs on a registered basis.

The “small AIFM” category is based on aggregate assets under management (AUM). Under Article 3(2) AIFMD, an AIFM is treated as small where the total value of all the portfolios it manages, including leverage, does not exceed €100 million, or does not exceed €500 million where the portfolios are unleveraged and investors have no redemption rights for five years after they invest.^[4]

The Small Registered Regime is available for three fund types and their AIFMs: (1) internally managed, closed-ended investment companies (for example, certain investment trusts); (2) property AIFs that are collective investment schemes holding most of their assets as land, managed by small property AIFMs; and (3) AIFs using the Social Entrepreneurship Fund (SEF) or Registered Venture Capital Fund (RVECA) labels. Small registered UK AIFMs are subject to the reporting and transparency requirements that apply to AIFMs under Article 3 AIFMD and the UK AIFM framework, while full-scope and small authorised UK AIFMs are also subject to the broader FCA requirements under the UK AIFM regime.^[5]