A number of fund managers continue to utilise the transitional arrangements in EU member states. These arrangements have the effect of delaying the requirement to make any filings in connection with marketing in the EU. These arrangements will terminate in July 2014, and fund managers will need to give some consideration to any necessary filings in Jersey and in their funds’ target markets in the EU. Any Jersey funds managed by an EU AIFM (which may be the case with a number of listed funds that have appointed UK managers) should be aware that the UK’s Financial Conduct Authority has issued a request for applications to be an AIFM to be made by January 2014. This date reflects an AIFMD deadline of July 2014 (after transition) and builds in an FCA three month review period plus an additional potential three month extension, and therefore is regarded by some industry commentators as a conservative deadline.

The JFSC has not yet issued any statements or guidance in relation to processing applications for AIF services business, but it is possible that there will be a rush of applications in the period running up to July 2014. It is advisable, therefore, to give thought now to any necessary filings (and related prospectus updates) to ensure continued access to EU markets from July 2014.