Original question
Original language
Answer provided by the European Commission
Yes, in principle, the ELTIF Regulation and Commission Delegated Regulation (EU) 2024/2759 do not prevent an ELTIF manager from setting out a redemption frequency that is more frequent than a weekly redemption, for instance, bi-weekly or a daily redemption.
ELTIF managers have the discretion to calibrate the percentage referred to in Article 18(2), first subparagraph, point (d), of the ELTIF Regulation by selecting either Annex I or Annex II of Commission Delegated Regulation (EU) 2024/2759. Both Annexes refer to weekly/monthly “or more frequent” redemptions. This is also consistent with Recital (11) of Commission Delegated Regulation (EU) 2024/2759, which refers to the flexibility in calibrating the liquidity parameters (thus, allowing redemption frequency different from those laid down in Annex I and Annex II of Commission Delegated Regulation (EU) 2024/2759).
In this connection, when an ELTIF manager determines the redemption frequency, that manager must take into account, among others, the following obligations. Article 5(2)(d) of Commission Delegated Regulation (EU) 2024/2759 sets out that when adopting the redemption policy of an ELTIF, in assessing the liquidity profile of the ELTIF, the manager of the ELTIF shall take into account the methods and documented process for the valuation of the assets of the ELTIF. Furthermore, ELTIFs must ensure the alignment and coherence of an ELTIF’s investment strategy with its liquidity profile and redemption policy of the ELTIF. In addition, in the interest of transparency and investor protection, the manager of an ELTIF should provide the competent authority of the ELTIF with certain minimum information that demonstrate that the ELTIF has in place an appropriate redemption policy and liquidity management tools that are compatible with the long-term investment strategy of the ELTIF.
Disclaimer
The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.