Position on the ELTIF proposal


FESE supports the European Commission’s proposal to revise the European Long-Term Investment Fund (ELTIF) Regulation. With its aim to facilitate investment by institutional and retail investors in long-term projects including social, infrastructure and SMEs, it has the potential to benefit the real economy and contribute to achieving a true Capital Markets Union (CMU).

In particular, FESE welcomes the following proposals:

  • an increase to the upper threshold of Small- and Medium-Capitalisation Companies (SMCs) to a market capitalisation of EUR 1 billion over 12 months.
  • removal of the partial duplication of suitability assessment referred to in the ELTIF Regulation and MiFID II.

FESE also believes that the listing of ELTIFs could act as alternative to the described redemption mechanism of the Funds before their maturity. Further, while a potential transfer mechanism of units or shares between exiting and potential new investors can promote secondary trading, such a mechanism should only be possible when a matching policy – that complies with certain information requirements – has been put in place by the ELTIF manager.