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  • Tracker Service

  • This page is from the Tracker Service September 2014 launch, and is only updated for Tracker subscribers

    One of the more contentious aspects of AIFMD is the Directive’s depositary requirements. The AIFMD depositary requirements are driven by a combination of the domicile of the manager, the fund and the approach taken to marketing the regulated AIF.

    Only EU AIFM managing are subject to the full depositary regime, whereby a single depositary is required to perform the three core depositary duties of safe keeping of assets, cash flow monitoring and oversight. Under this model, the depositary is required to take on the strict liability for loss of financial instruments.

    However, EU AIFM managing a non-EU AIF and marketing (defined broadly as at the initiative of the manager either directly or indirectly through a third party) via private placement as opposed to reverse solicitation (at the initiative of the investor) are subject to a ‘depositary-light’ or ‘depolite’ regime. This requires the AIFM to “ensure one or more entities are appointed to carry out” the three core depositary duties noted above.

    Because strict liability does not apply and multiple firms can be used this has been called the ‘depo-lite’ model. The Tracker will, in particular, monitor the development of ‘depo-lite’ service providers as well as full depositaries. It will seeking to find out if AIFMD’s ‘depo-lite’ services turn out to be a just a regulatory box ticking exercise or something that could be of real value to investors.

    Organisations known to The Tracker offering depositary services:
    • Alter Domus
    • Augentius
    • Aztec
    • BNP Paribas
    • BNY Mellon
    • Caceis
    • Centaur
    • Citco
    • Credit Suisse
    • Heritage
    • Intertrust
    • Indos
    • Ipes
    • Northern Trust
    • Orangefield
    • SS&C GlobeOp
    • SuMi TRUST