The Council of the EU has published a note on the Presidency’s general approach on the proposed European Long-term Investment Funds Regulation (ELTIF Regulation). The note includes a joint statement by the UK and Estonia.
The statement confirms that the UK and Estonia support the general approach in the interests of the progress of the file but they remain concerned about the requirement for retail investors to commit to a minimum investment of EUR 10,000 that has been inserted into Article 24(1)(-ac). They argue that this requirement undermines the original policy intention of creating an EU regime suitable for retail investors, and that it could severely restrict uptake.
The UK and Estonia also believe that a minimum subscription is a poor method of determining the appropriateness of a product for an investor. Basing appropriateness on an advised sale process would better meet the proposal’s policy aim and also provide more robust protection for European consumers. They state that they will seek to address this issue in the trialogue process.