Applying for a permission

Small Scheme Manager

Small Scheme Manager

The purpose of this page is to explain the application process for Small Scheme Managers. 

This section sets out:

  • What a Small Scheme Manager is and what this regulated activity would allow you to do
  • Authorisation Process
  • Capital Requirements 
  • Additional Information

What is a Small Scheme Manager and what would this regulated activity allow you to do?

A Small Scheme Manager is an AIFM that manages portfolios of AIFs whose assets under management do not exceed a threshold of EUR 100 million, EUR 500 million when the portfolios of AIFs consist of AIFs that have no redemption rights for five years following the date of initial investment in each AIF.

Small Scheme Managers must register as such with the GFSC and comply with the conditions applicable to Small Scheme Managers. AIFMs that manage AIFs whose assets exceed the thresholds set out above require an Alternative Investment Fund Managers (AIFM) authorisation. 

A Small Scheme Manager’s permission allows an AIFM to manage AIFs whose assets under management do not exceed the de-minimis thresholds set out above and which do not elect to opt-in to the full authorisation process under the AIFMD. 

 

Application process

Applicants should submit an application pack with all relevant documents. We will not consider an application complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee;
  • Application Form;
  • Authorised AIFM (B2) Reporting Template;  
  • Financial Projections for the next 3 years;
    • Stress Test on Financial Projections;
    • Profit and Loss account;
    • Balance Sheet;
  • Regulated Individual Form (for each Regulated Individual);
  • Non-Executive Director Form (for each non-executive director);
  • Controller Form (for each Controller);
  • Business Plan;
  • Details of the AIFs it intends to manage:
    • the investment strategies of the AIFs that it intends to manage, including the types of underlying funds, the AIFM’s policy on the use of leverage and the AIFM’s risk profiles;
    • the constitutional or organisational documents of each AIF it intends to manage; and
    • arrangements made for the appointment of the depositary for each AIF.
  • Risk methodology and/or threat assessment matrix; 
  • Mapping assessment of how the application meets the relevant legislative threshold requirements (i.e. statutory/regulatory criteria for licensing under relevant Act); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

Please request cloud access via E-mail at authorisations@gfsc.gi  in order to submit the Application Pack. Please include the following information in the subject field: ‘Name of Regulated Firm/Applicant – Application’. Paper copies are not required unless indicated by the Authorisation team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

 

Capital Requirements

Small Scheme Managers are required, on an ongoing basis, to self-assess the level of financial resources required to be able to meet its liabilities and ensure an orderly wind-down, subject to a minimum of £15,000. In granting an authorisation, the GFSC may require a Small Scheme Manager to maintain financial resources at a level that is higher than the self-assessed level. 

 

Additional Information

The business plan should comprehensively set out:

  • The firm’s proposed activity and how it will be conducted;
  • The resources that will be made available and the systems that the applicant intends to employ;
  • How clients will be attracted;
  • What arrangements will be put in place to safeguard client monies and/or assets;
  • How records will be maintained;
  • How, and by whom, any significant decisions will be made;
  • How the firm complies with the Anti-Money Laundering requirements; 
  • The level and nature of fees to be charged to the firm’s clients; and
  • If the applicant forms part of a larger group, details should also be provided of the activities of the group and a description of their structures.

The GFSC will also be seeking evidence that the firm has considered, documented and implemented the risk, compliance and operational issues associated with the proposed activities.

Firms should consider the relevant AIFMD requirements in their entirety prior to submitting an application. The GFSC Information Pages may also be of assistance as they set out the requirements specific to the relevant area.