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By Dr. Sebastiaan Niels Hooghiemstra*
On 26 March, the final legislative text of the directive amending Directive 2011/61/EU (“AIFMD”) was published in the Official Journal of the EU (“AIFMD 2”). Whilst AIFMD 2 does not completely overhaul the AIFMD framework, it does raise a number of noteworthy changes. One of those are the new rules for loan-originating alternative investment funds (“LO-AIFs”), AIFs which originate loans (“AIFs-WOL”) and alternative investment fund managers (“AIFMs”) managing AIFs-WOL (“LO-AIFMs”). This contribution discusses the uncertainties in relation to the “AIFMD 2 lending passport”.
Background: Not Quite Yet an “AIFMD Lending Passport”
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