The Malta Financial Services Authority (MFSA) has announced the launch of a new consultation process to introduce Self-Managed Notified Professional Investor Funds (SM NPIF). This initiative aims to enhance Malta's investment environment by providing a more streamlined framework tailored for professional investors.
This new proposal mirrors the Notified Professional Investor Fund (NPIF) framework introduced in January of this year, with key differences pertaining to the management function and specific aspects of the Alternative Investment Fund Managers (AIFM) Directive applicable to the scheme's internal management.
Key aspects of the proposed requirements include:
- Initial Capital Requirements: The scheme must maintain an initial paid-up share capital of at least €125,000 (or its equivalent in another currency). Additionally, the Net Asset Value (NAV) must consistently exceed this threshold, aligning the capital requirements for a Self-Managed NPIF with those for a licensed Self-Managed Professional Investor Fund (PIF).
- Investment Committee: The scheme must appoint at least three Investment Committee members, including at least one portfolio manager who may also serve on the Investment Committee and/or the Board of Directors.
- Due Diligence by the Service Provider: Under the current NPIF framework managed by third parties, the Due Diligence Service Provider (DDSP) evaluates the suitability of the third-party manager, who must be authorized by the MFSA, an EU/EEA state, or a comparable third country. For Self-Managed NPIFs, however, the DDSP focuses on assessing the qualifications and experience of the Portfolio Manager and Investment Committee members, rather than relying on the regulatory status of a third-party manager.
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