Hard Brexit Impact Analysis

Page 35 of 106 Category If no agreement is reached: Consequence EU Document Finance Asset management As of the withdrawal date Branches of UK managers (permanent presences which are not legally independent from the AIF manager) in the EU will be treated as branches of a non-EU AIF managers as of the withdrawal date. These branches will be subject to the requirements of NPPRs, where available. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF ASSET MANAGEMENT Finance Asset management EU ASSET MANAGEMENT ACTIVITY: As of the withdrawal date, UCITS and AIFs authorised or registered in the United Kingdom in accordance with the Directive 2009/65/EC or Directive 2011/61/EU will be non-EU AIFs (see above). EU 27 UCITS management companies managing those (former) UCITS authorised in the UK will need to obtain an authorisation according to Article 6 of Directive 2011/61/EU to manage non-EU AIFs. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF ASSET MANAGEMENT Finance Asset management EU ASSET MANAGEMENT ACTIVITY: As of the withdrawal date , the management, by AIF managers established and authorised or registered in the EU, of non-EU AIFs that are not marketed in the EU must comply with Directive 2011/61/EU (except depositary and annual report rules) and cooperation agreements for exchange of information between EU competent authorities and the relevant third country authorities (Article 34 of Directive 2011/61/EU). WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF ASSET MANAGEMENT Finance Asset management EU ASSET MANAGEMENT ACTIVITY: As of the withdrawal date According to Article 36 of Directive 2011/61/EU, the marketing of non- EU AIFs managed by an AIF manager established and authorised or registered in the EU is subject to the NPPR, which is an option for Member States. Stricter rules may be imposed on this category of AIF managers by Member States. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF ASSET MANAGEMENT Finance Asset management EU ASSET MANAGEMENT ACTIVITY: Before of the withdrawal date According to the rules on disclosure to investors in Directive 2009/65/EC and Directive 2011/61/EU, UCITS management companies and AIF managers must take a number of steps to inform investors of the consequences of the withdrawal of the United Kingdom from the EU WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF ASSET MANAGEMENT