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ELTIF, Private Investors

From Niche to Spotlight? The Future of ELTIFs

It's a financial product that few have known so far: ELTIF. After the reform of EU regulations, ELTIFs are likely to become more attractive – for both fund issuers and investors.

What is an ELTIF?

ELTIF stands for European Long-term Investment Fund. It represents a set of EU regulations that determine the structure of financial products. ELTIFs are designed to allow retail investors to invest in long-term and illiquid projects, such as non-listed investment assets like infrastructure projects, private equity, real estate, and private debt.

In concept, an ELTIF is a closed-end fund with a limited term. Legally, it is considered an Alternative Investment Fund (AIF).

With its initiative in 2015, the EU aimed to not only introduce new, highly regulated financial products to retail investors but also to bridge the investment gap in infrastructure, which has since grown larger due to the energy transition.

The ELTIF market has been slow to gain traction, especially in Germany, even though ELTIFs can be distributed throughout Europe thanks to EU Passporting. One of the most well-known ELTIFs in Germany is the Commerz Real fund, klimaVest.

What was the issue with ELTIFs?

The extensive regulatory framework for ELTIFs was, until now, as complex as it deterred both providers and (private) investors. Critics in the market argued that the barriers for retail investors were too high, and the establishment and distribution process were too restricted. Additionally, there was a call to better consider the interests of institutional investors, which many ELTIFs targeted.

What changes with the ELTIF reform?

The EU responded to the criticism: In late October 2022, negotiators from the Council and the European Parliament reached a preliminary agreement on a regulation reform. The changes come into effect nine months after publication in the EU Official Journal, expected to be at the end of 2023. At that time, the following rules are expected to apply to ELTIFs:

  • All tangible assets can be invested in if they are assessable due to their characteristics and nature, including, among others, water or forestry rights.
  • Real estate no longer needs to demonstrate a specific economic or social benefit.
  • The minimum investment volume for individual assets in the fund is reduced from €10 million to €1 million.
  • Investments can be made in AIFs, UCITs, and securitization instruments.
  • Instead of the previous requirement of 70%, only 60% of the fund’s assets must be invested in eligible assets, including tangible assets.
  • An individual asset can constitute up to 20% of the fund’s assets, as opposed to the previous limit of 10%.
  • The leverage ratio is increased from 30% to 50%.
  • The borrowed capital can also be used for liquidity purposes, not just for specific investments.
  • For ELTIF funds exclusively targeting institutional investors, numerous diversification requirements are waived, allowing for, among other things, single-asset funds. In this case, a leverage ratio of 100% is permitted.
  • There is no longer a minimum investment amount per investor, as there used to be a requirement of €10,000 per fund, applicable only to investors with assets of up to €500,000. Such ELTIF-specific distribution and portfolio requirements for the investor are no longer applicable.
  • MiFID II-compliant advice from a distribution partner is sufficient.
  • The explicit warning for maturities exceeding 10 years remains necessary.

Why should investors now consider taking a closer look at ELTIFs?

Investing in infrastructure projects offers stability and the potential for solid returns. In addition, investors get to actively support the energy transition. For funds focusing on Private Equity, experts estimate returns after costs at 10 to 12 %, for infrastructure at 5 to 8 %, and for private credit funds at 3 to 4 % – although such forecasts should always be taken with caution and depend on the specific product and its management.

Furthermore, the costs associated with ELTIFs are lower than many other products. According to the rating agency Scope, the annual management fees for ELTIFs with a minimum investment amount of less than €100,000 range between 0.95 % and 2.5 %.

What should ELTIF investors be mindful of?

Investing in an ELTIF involves a long-term commitment, as there is typically no secondary market, even though early redemption options may be available. Comparing ELTIFs directly with one another can be challenging due to their diverse investment strategies.

Why should fund issuers and distributors consider looking at ELTIFs now?

Following the revision of stringent regulations and the establishment of a common EU standard, the process of creating and distributing these products will become more accessible and cost-effective. The elimination of minimum investment requirements will significantly expand the potential customer base. New distribution platforms will simplify marketing and sales efforts, opening doors to new customer segments. With only an appropriateness test required instead of a suitability test, this change presents distributors with entirely new opportunities.

Scope has already observed market growth. Particularly since the end of 2021, there has been increased momentum in discussions with banks and third-party providers such as fund platforms, as highlighted in the study.

Hence, the groundwork for a second, promising initiative is in place.