FR AMF Master-Feeder Doctrine


On Apr. 22, FR AMF updated its doctrine re master-feeder structures.


  • FR AMF has updated its doctrine concerning gates in master-feeder structures.
  • Follows FR GVT Apr. 2024 approved amendments to Book IV of RGAMF, see #209059.
  • Main Points
  • Following approval of the amendments to its General Regulation (RGAMF), FR AMF updated its policy on the capping of redemptions (gates) in master-feeder structures.
  • Updated Instruction DOC-2017-05 procedures re liquidity management mechanisms.
  • In order to introduce a mechanism whereby, when a master collective investment undertaking (CIU) triggers its gates, its feeder can trigger its gates at its own level.
  • This option enables the feeder CIU to avoid having to suspend redemptions altogether.
  • For this mechanism to apply the feeder CIU must execute at least the proportion of redemptions executed by the master CIU; the capping must be in the prospectus.
  • And also in the fund rules or articles of incorporation of the feeder CIUs and they must specify the procedures for capping redemptions of units or shares by the master CIU.
  • Also, the information exchange agreement between the feeder and the master CIU must specify how the master will inform the feeder if the redemption cap is triggered.
  • Change to rules for employee savings plan investment funds if the gates are triggered.
  • Relevant policy documents updated, extending transitional period re gates incentives.
  • I.e., Instruction DOC-2011-19 on authorization procedures, preparation of a KIID and a prospectus and periodic reporting for French and foreign UCITS marketed in France.
  • Instruction DOC-2011-19 and annex XI with apparent changes (in French only).
  • Instruction DOC-2011-20 on authorization procedures, preparation of a KIID and a prospectus and periodic reporting for retail investment funds, funds of alternative funds and professional alternative investment funds (in French only).
  • Instruction DOC-2011-20 and annex XII with apparent changes (in French only).
  • Instruction DOC-2011-21 on authorization procedures, preparation of a KIID and a prospectus, and reporting for employee investment undertakings (in French only).
  • Instruction DOC-2011-21 and annexes XI XII with apparent changes (in French).
  • Instruction DOC-2011-22 on authorization procedures, preparation of a KIID and rules, and reporting for private equity funds and with apparent changes (in French only).
  • Instruction DOC-2012-06 on procedures for making disclosures and introducing changes, preparation of a prospectus and reporting for specialized professional funds and professional private equity funds; and with apparent changes (in French only).
  • DOC-2017-05 on conditions to set up redemption gate mechanisms; with changes.
  • Effectiveness
  • Feeders funds can introduce capping of redemptions (gates) until Dec. 31, 2024.
  • If they fail to do so before that date, they must inform FR AMF, state the reasons, and also include a warning in the fund documentation.

Regulators FR AMF
Entity Types HF; IA; Inv Co
Reference PR, 4/22/2024; RGAMF; DOC-2011-19; DOC-2011-20; DOC-2011-21; DOC-2011-22; DOC-2012-06; DOC-2017-05
Functions Compliance; Financial; Operations; Product Administration; Treasury
Countries France
Category
State
Products Fund Mgt; Hedge Funds; Securities
Regions EMEA
Rule Type Final
Rule Date 4/22/2024
Effective Date 12/31/2024
Rule Id 209540
Linked to Rule :209059
Reg. Last Update 4/22/2024
Report Section EU

Last substantive update on 04/25/2024