Questions and answers on regulations on CISs, Venture Capital Firms and other collective investment vehicles

The CNMV has updated its Q&A document with the following 18 changes:
Page 57: A new question (82 ter) has been added, inquiring about the criteria used by CNMV to require additional warnings for certain investment funds with specific return objectives. The communication also highlights the importance of considering management fees in relation to expected returns.
Page 71: A new question (101 bis) asks if a Spanish IICIL can invest more than 50% in a single foreign IICIL or similar foreign institution.
Page 116: Four new questions (9 ter, 9 quáter, 9 quinquies, 9 sexies) discuss the limitations of SGEIC regarding debt and credits and address the formation and functioning of investment committees within a management company.
Page 122: The information that a SGEIC must submit to the CNMV for registration is updated in the question (19).
Page 124: The minimum initial equity requirements for FCR and FCRPyme are discussed, along with the minimum equity for FCRE, FESE, and EICC in the new question (23 ter) and the update of question (25).
Page 129: The conditions that must be communicated to the CNMV for the modification of the initial authorization of an SGEIC are clarified in the updated question (36).
Page 130: The registration of SGEICs for cross-border activities and the need for a depositary for each fund managed by the SGEIC are explained in the new question (37 quáter).
Page 131: The possibility of making portfolio transfers between managed vehicles and the use of cash subscriptions are discussed in the new question (37 quinquies).
Page 132: The possibility of in-kind distributions upon liquidation and dissolution of the funds is addressed in the new question (37 sexies).
Page 132: The use of global accounts for marketing closed-end funds is discussed in the new question (37 septies).
Page 133: The concept of premarketing is introduced in the update of question (39), allowing for the communication of investment strategies or ideas to potential professional investors prior to registration.
Page 133: The maximum duration for the marketing of a fund and the possibility of establishing different entry prices for investors during the placement period are explained in the update of question (40).
Page 136: Shares of ECR in Spain can only be marketed to professional clients, and retail investors cannot request to be treated as professionals without meeting specific requirements, which is clarified in the new question (46).
Page 138: If ECRs are exclusively marketed to professional investors, there is no need to provide the KID PRIIPs. However, if a retail investor initiates the investment on their own, the KID PRIIPs must be provided to them, which is clarified in the updated question (51).