Overview
- Closed-ended AIF schemes may base investor rights on total commitments or undrawn commitments, with the chosen method disclosed in the PPM and fixed for the scheme’s tenure.
- Open-ended Category III funds are exempt from pro-rata drawdowns but must distribute proceeds in proportion to units held, and they follow closed-ended rules when investing in unlisted securities.
- Investments made on or before December 13, 2024 can be distributed under previously disclosed terms, and compliant existing schemes may continue their current approach for those assets.
- Carried interest shared with fund managers is excluded from the pro-rata requirement, and managers must maintain compliance records that trustees confirm in periodic reports.
- The draft prohibits redeploying unused commitments of investors excluded from specific deals and requires methodologies that prevent breaches of investor concentration limits, with industry feedback noting unresolved issues around differential fees and operations.