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ESMA_QA_2480
Topic
14/03/2025
Subject Matter
Dividend entitlement date
Question
May an ELTIF define a minimum period before which the shares cannot benefit from distributions of the ELTIF?

May the setting of a minimum holding period during which investors cannot benefit from the distributions of the ELTIF be considered as a “fee" or a “cost”, as per the requirements of Article 25 of the ELTIF Regulation?
ESMA_QA_2478
Topic
14/03/2025
Subject Matter
Redemption policy
Question
Given the requirements set out in Article 17(1) point a) and 18(2) point a) of the ELTIF Regulation, as well as in Article 3 of the ELTIF Delegated Regulation, is the minimum holding period, referred to in Article 18(2) point a) of the ELTIF Regulation, assessed in relation to the launch date of the ELTIF for all investors, or is it applied at each new subscription and on the basis of the date of each capital contribution if there is more than one investment by an individual investor?
ESMA_QA_2476
Topic
14/03/2025
Subject Matter
Redemption policy
Question
Can an ELTIF use borrowings, as referred to in Article 16(1) of the ELTIF Regulation, to meet redemptions?

Can confirmed but undrawn credit lines be considered as “expected cash flows”, as referred to in Article 5(6) of the ELTIF Delegated Regulation, and thus be taken into account in the maximum limit referred to in Article 18(2), point (d) of the ELTIF Regulation?

What are the criteria to assess the “prudent” nature of the expected cash flows forecasted […] over 12 months, as referred to in Article 5(6) of the ELTIF Delegated Regulation that could be added to the maximum size of redemption at a given redemption date?

For private debt ELTIFs, what elements should be taken into account in the abovementioned "expected cash flows"?