The mini-manager opportunity
Introduction of Mini-Managers to Cyprus regulatory scene through the enactment of the Incorporation and Operation of Small Alternative Investment Fund Managers Law (81(I)/2020), (the “Mini Managers Law”), has made Cyprus an even more attractive jurisdiction for both global asset managers to setup shop.
The Mini Managers Law gives the opportunity of incorporating and operating a licensed fund manager with lower capital requirements and lower maintenance costs to accommodate for small-scale investments. It also allows international wealth managers to establish local presence for management of their Cyprus investment projects.
Mini Managers can manage and market Cyprus, EU or third-country Alternative Investment Funds (“AIFs”) with assets under management not exceeding the below thresholds:
• EUR 100.000.000, including leverage, or
• EUR 500.000.000, without leverage and with a lock-up period of 5 years.
A Mini Manager is under the regulatory supervision of the Cyprus Securities and Exchange Commission (“CySEC”) and as part of its authorisation application, it must present for assessment the CySEC Questionnaire containing information about each of its board of directors, senior management and shareholders with qualifying holdings, a business plan and internal operations manual, depositary appointment arrangements and the investment strategy of the AIFs it intends to manage.
Further, it must appoint in its organisational structure at least four directors (two executive and two non-executive), an internal auditor, an Anti-Money Laundering Officer and a Risk Manager.
A Mini-Manager can provide services such as portfolio and risk management, administration services, and marketing activities in a manner identical to that of fully-fledged Alternative Investment Fund Managers.
The efficiency and attractiveness of the Mini-Managers lie in the low cost, short time, simplified incorporation/licensing process, and reduced initial capital requirements (EUR 50.000).
Our firm welcomes all your queries and considerations, and will be happy to give you guidance and support customised to your plans and projects, so that you can make full use of the Mini-Manager opportunity in your worldwide ventures.
Authors: Huseyin Erguven, Polyvios Nicolaou