Jersey Finance: NPPRs are here to stay

Opinions differ on the long-term use of national private placement regimes as an alternative to the AIFMD passport.

According to a recent sponsored article by Alter Domus, national private placement regimes “are gradually being abolished”, and will no longer be available by August 2021. We referenced this position in our daily email on September 20. Jersey Finance CEO, Joe Moynihan contacted Private Funds CFO to dispute the claims. His response in full:

Dear Sir,

There were some incorrect assertions made in this newsletter last week concerning the future of National Private Placement Regimes that need to be robustly challenged.

Based on incorrect information, this daily newsletter made reference to the ‘disappearance’ and ‘removal in 2021’ of NPPRs. This is entirely factually incorrect. The truth is that private placement not only remains available, but remains a hugely attractive option for the majority of non-EU managers looking to fundraise in the EU.

The AIFM Directive is, in fact, very clear on the fact that private placement will remain in existence until at least three years after the extension of the passport to third countries, whilst one of the key recommendations of the KPMG report published for the European Commission at the end of last year was that private placement was working well and should be left untouched.

In fact, the EU’s own figures show that 97 percent of European funds market to three countries or less. In these cases, private placement offers a much more flexible, cost-effective route than full blanket passporting. It’s why, in our case, Jersey has seen the number of alternative fund managers using private placement rise consistently over recent years, so that now more than 170 managers market more than 300 funds into the EU. It’s a route that is proven to work well and that will continue to work well.

It is highly concerning that misleading comments about the future of private placement are presented in this way, particularly at a time when managers need certainty and clarity more than ever before.

For its part, Jersey is ready to support managers now and will continue to support through the tried-and-tested private placement route into the future, for years to come.

Kind regards,

Joe Moynihan

CEO, Jersey Finance

Alter Domus did not respond to the assertions in the above letter.