Manx State of the Nation

1
Manx State of the Nation

• Break Out Session
• Fund Management and Administration IOM
  Collective Investment Schemes

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Because you can
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Fund Management Administration- IoM Collective
Investment Schemes

• Isle of Man Compliance Institute
• Manx State of the Nation Conference
• 24th January 2008

4
Isle of Man Funds Industry - A very active year!

• Further progress in the level of FUM/FUA
• Delivery of FRG Report to Treasury Minister
• Implementation of FRG recommendations
• Key initiatives undertaken
• Significant Legal and Regulatory change
• Plans and challenges for the future

5
Progress in level of FUM / FUA

• Low point end 2002 of U7bn
• End Sept 2007 U53bn
• End Dec. number subject to markets but number of
  new funds mandates increasing
• Progress on New Hedge Fund Managers with two
  set-ups
• Target FUM / FUA of U150bn by end 2010

6
Funds Industry Review

• Commissioned by Treasury Minister October 2006
  under independent Chairman
• Terms of reference were to
• Identify reforms to legal, regulatory and fiscal
  framework to enhance future growth of Islands
  Funds Industry
• Recommend future structuring of marketing and
  promotion of Islands Funds sector
  internationally
• Wide representation within Review Group
• Reported to Treasury Minister February 2007
• Implementation Group formed May 2007 to drive
  forward key recommendations
• Legal and Regulatory recommendations now in
  place, Marketing program ongoing

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FRG Report / Key findings

• Visibility
• Very low in International Funds marketplace
• Strategy
• Increased targeting of Institutional Fund
  Management business especially within the
  alternative segment
• Need to develop consistent marketing focus and
  messages
• Need to update and differentiate Product Offering
  from competitors
• Resources
• Continued close cooperation between Funds
  Industry and IoM Finance
• Significant increase in Marketing Funding vital
• Recruitment by IoM Finance of additional
  specialist dedicated resources

8
FRG Report / Key recommendations

• Rationalise existing fund classes EIFs / PIFs
• Seek to attract Fund incorporation / domicile,
  together with Fund Administration
• New class of fund to focussed on Institutional
  business Specialist Fund
• Seek to attract Fund Management activity
• New regulatory structure to facilitate relocation
  of front / middle office functions by Hedge
  Managers

9
Implementation of FRG Key initiatives undertaken

• Successful application to Marketing Initiative
  Fund - 580,000
• New scheme classes introduced QF / SF and EIF
  transition
• Revised regulatory environment for new Hedge
  Manager set-ups
• Re-Launch of Industry at InvestHedge event in
  London Sept. 2007 main sponsor / media cov.
• Working closely with IFI
• Hedge Manager targeting program
• Round Table event Program

10
Marketing ProgramPlans / challenges for the
future

• Two major Conference events in 2008
• EuroHedge Paris 16/17 April
• InvestHedge London 23 / 24 Sept
• Other Conference events
• SII Investing in Hedge Funds 7th Feb
• IFI Round Table events London / US
• Hedge Manager targeting program

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Marketing ProgramChallenges

• Funding
• MIF allocation spent by end 2008 / more
• Resourcing
• IoM Finance fully committed
• Increased level of resource needed
• Industry Commitment
• Support planned initiatives
• Train and educate your staff

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Because you can
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Because you can
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Topics

• Important concepts
• Revised categories of fund
• Common requirements under the new regime
• Specific features of new categories
• Timetable for EIF transition
• Decision-making for EIF transition

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Important Concepts

• Governing body essentially the board of
  directors relevant to all funds considerable
  responsibilities for overall operation/compliance
• Manager an IOM licence holder difficult to
  explain in terms of functions may or may not
  undertake administration and/or asset management
  primarily a product of allocation of regulatory
  responsibility
• Administrator an IOM or (for a specialist fund)
  overseas licence holder can mean different
  things in different contexts responsibilities
  vary with category of fund responsible like a
  manager in some cases

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Important Concepts

• Asset manager discretionary manager of
  investments on behalf of the fund can be based
  anywhere and will not necessarily be licensed
• Investment adviser provider of investment
  advice in relation to investments to the
  governing body i.e. no authority to bind fund
  can be based anywhere and will not necessarily be
  licensed
• Promoter a person who prepares or distributes
  (or causes the preparation or distribution) of an
  offering document or marketing materials will be
  an IOM licence holder (category 1(c)) or
  regulated abroad

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Important Concepts

• Custodian covers both fiduciary and
  non-fiduciary custodians expressly includes
  prime brokerage must be IOM authorised person or
  appropriately regulated overseas
• Qualifying auditor member of professional body
  permanent place of business in the IOM PII of no
  less than 20M independent of fund
• Acceptable financial adviser relevant to
  paragraph (h) certified investors appointed by
  promoter who must assess suitability and ensure
  appropriate written terms of business are in place

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Revised Categories

• Experienced investor fund no longer available
• Specialist fund for new funds/converted EIFs
• Qualifying fund for new funds/converted EIFs
• Qualifying type EIF for continuing EIFs only
• Legacy EIF for continuing EIFs only
• Closed EIF for continuing EIFs only
• Exempt scheme unchanged
• Professional investor fund unchanged
• International scheme - unchanged

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Common Requirements

• Governing body independent natural person on
  board
• Investment services governing body must obtain
  suitable investment management or advisory
  services
• Financial statements prepared/audited to UK
  GAAP/IFRS and distributed within 6m of year-end
• Qualified auditor must audit financial
  statements
• Custodian where required must be licensed
  governing body must be satisfied that it is
  appropriately experienced for the class of
  assets

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Common Requirements

• Investors must be sufficiently experienced in
  ALL cases AND must fall within prescribed
  permitted categories
• Common permitted investor categories
  professional investors, affiliates, public
  bodies
• Additional permitted investor categories high
  net worth investors, certified investors
  (depends on category)
• Offering document governing body take
  responsibility must contain all material
  information and must be updated to reflect
  material changes revised health warnings

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Common Requirements

• Responsibility statement governing body signs
• Annual compliance declaration governing body
  signs and manager signs in case of Qualifying
  Fund or Qualifying Type EIF
• New notification form manager/administrator
  must submit on establishment and material
  alteration
• Quarterly statistical returns manager/
  administrator must submit
• Investor declarations new expanded forms of
  certificates for investors to sign including
  awareness of risk of loss, confirmation of
  independent advice and specific certificates for
  life office investors

22
Common Requirements

• Whistle-blower requirements on manager/administrat
  or non-compliance with requirements, departure
  from governing body, qualified audit opinion,
  delay in distributing financial statements
• Auditor notifications auditor who leaves office
  is required to make a direct notification to the
  FSC as to whether circumstances connected with
  departure of which FSC should be aware
• Auditor whistle-blowing not in place yet but
  likely to be included in new Collective
  Investment Schemes Bill

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Specialist Fund

• Administration no need for manager licensed
  administrator required, but need not be in IOM
• Foreign administrator if appointed, there must
  be an IOM director covered by IOM CSP licence
• Permitted investor categories professional
  investors, affiliates, public bodies, high net
  worth investors i.e. net worth over US1M
  (excluding principal residence) NO certified
  investors
• Minimum initial investment US100K
• Existing investors in EIF or PIF if an existing
  EIF or PIF at 01/11/07 converts by 01/05/09 then
  existing investors prior to conversion are
  grandfathered, even if they invested after
  01/11/07, PROVIDED (in case of EIF) it always had
  US100K minimum initial investment
• No custodian required

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Qualifying Fund

• Management must be a licensed IOM manager
• Investment services manager must approve
  provider
• Annual compliance declaration manager must sign
  as well as governing body
• Licensed promoter required can be IOM
  licenceholder (see category 1(c)) or licensed
  elsewhere, but query whether equivalent
  legislation in place
• Custodian required
• Minimum initial investment an appropriate level
  must be set by governing body/manager, but none
  prescribed by law

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Qualifying Fund

• Permitted investor categories professional
  investors, affiliates, public bodies and
  certified investors i.e. no wealth requirement
• Certified investors must have certificate from
  acceptable financial adviser
• Acceptable financial adviser must be approved
  by promoter in light of
• (a) compliance with applicable regulations
• (b) competence, qualifications and experience
• (c) procedures/controls for fund
  distribution/investor record-keeping

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Qualifying Fund

• Acceptable financial adviser must have written
  terms of business with promoter requiring the
  adviser
• (a) to undertake customer due diligence,
  including experience and suitability
• (b) to maintain records pertaining to (a)
• (c) only to sell the fund to qualifying investors
  
• Existing investors in EIF or PIF if an existing
  EIF or PIF at 01/11/07 converts by 01/05/09 then
  existing investors prior to conversion are
  grandfathered, even if they invested after
  01/11/07

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Closed EIF

• Summary regime for existing EIFs with fewer
  requirements for change, provided fund is closed
  to new investment (even from existing investors)
• Timing must make decision to close, communicate
  this to investors and cease accepting investment
  all before COB 01/11/08
• Investment services provider required and
  governing body must be happy with suitability of
  provider
• Custodian must be regulated in IOM or overseas
  governing body must be satisfied as to
  appropriate experience

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Closed EIF

• Auditor must be qualified auditor
• Financial statements must be prepared/audited
  to IFRS/UK GAAP and distributed within 6m of
  year-end
• Whistle-blowing administrator subject to duties
• Promoter not required since no new investment
  may be accepted
• Licensed manager not required must be an IOM
  licensed administrator
• Existing exempt manager cannot continue to act

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Legacy EIF

• Summary regime enabling existing EIFs to
  upgrade to specialist fund type requirements even
  if they havent always had a US100K minimum and
  without changing management arrangements
• Timing must make decision to convert to Legacy
  EIF before COB 01/11/08 and implement by COB
  01/05/09
• Investment services provider required and
  governing body must be happy with suitability of
  provider
• Custodian must be regulated in IOM or overseas
  governing body must be satisfied as to
  appropriate experience

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Legacy EIF

• Minimum initial investment going forward,
  initial investments from new investors must be at
  least US100K
• Permitted investor categories similar to
  Specialist Fund, must be professional investors,
  affiliates, public bodies or high net worth
  investors i.e. no certified investors
• Existing investors dont have to have made
  minimum initial investment of US100K or to fall
  within permitted investor categories or to have
  given prescribed declaration

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Legacy EIF

• Auditor must be qualified auditor
• Financial statements must be prepared/audited
  to IFRS or UK GAAP and distributed within 6m of
  year-end
• Whistle-blowing administrator subject to duties
• Promoter not required since specialist
  investor type requirements going forward
• Licensed manager not required must be an IOM
  licensed administrator
• Existing exempt manager cannot continue to act

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Qualifying Type EIF

• Summary regime enabling existing EIFs to adopt
  Qualifying Fund features whilst retaining exempt
  manager
• Timing must make decision to convert to
  Qualifying Type EIF before COB 01/11/08 and
  implement by COB 01/05/09
• Manager IOM licensed manager or exempt manager
  required if exempt manager continues,
  administrator is responsible for discharge of
  managers duties e.g. whistle-blowing
• Investment services provider required,
  governing body must be happy with suitability of
  provider and manager must approve appointment

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Qualifying Type EIF

• Minimum initial investment none prescribed
  must be determined by governing body/manager
• Permitted investor categories as per Qualifying
  Fund, must be professional investors, affiliates,
  public bodies or certified investors
• Certified investors as per Qualifying Fund,
  must be certified by acceptable financial
  adviser
• Existing investors dont have to fall within
  permitted investor categories or to have given
  prescribed declaration

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Qualifying Type EIF

• Custodian must be regulated in IOM or overseas
  governing body must be satisfied as to
  appropriate experience
• Auditor must be qualified auditor
• Financial statements must be prepared/audited
  to IFRS or UK GAAP and distributed within 6m of
  year-end
• Whistle-blowing manager/administrator subject
  to duties
• Promoter required since qualifying investor
  type requirements going forward acceptable
  financial adviser required in order to accept
  investment from certified investors
• Existing exempt manager can continue to act

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Summary of Requirements
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Summary of Requirements
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Summary of Requirements
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Summary of Requirements
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Timetable for EIF Transition

• 01/11/07 from midnight on this date no new EIFs
  could be formed from
• 01/11/07 from midnight on this date no exempt
  managers for new EIFs could be established
• 01/11/08 if an EIF wishes to remove itself from
  scope of IOM fund regulation it must do so before
  midnight on this date
• 01/11/08 if an EIF wishes to convert to a
  Closed EIF, it must elect to do so, notify
  investors and cease accepting new investment
  before midnight on this date

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Timetable for EIF Transition

• 01/11/08 any other EIF must choose whether to
  convert to Legacy EIF, Qualifying Type EIF,
  Qualifying Fund or Specialist Fund and it must do
  so before midnight on this date
• 14/11/08 the governing body of any EIF which
  was still an EIF at midnight on 01/11/08 must
  submit a statement of responsibility as per
  Schedule 2 to the EIF Order (as amended) to the
  FSC before COB on this date specifying whether it
  will convert to Closed EIF (Part B), Legacy EIF
  or Qualifying Type EIF (Part A) or Qualifying
  Fund or Specialist Fund (Part C)

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Timetable for EIF Transition

• 01/05/09 any EIF which was still an EIF at
  midnight on 01/11/08 and did not convert to a
  Closed EIF must convert to Legacy EIF, Qualifying
  Type EIF, Qualifying Fund or Specialist Fund as
  previously notified to the FSC on a date falling
  on or before this date (the conversion date)
  no EIF can continue in existence after this date
• 10 working days after conversion date - governing
  body of converted EIF must submit a statement of
  responsibility as per Schedule 6 to the EIF Order
  (as amended) confirming conversion to Qualifying
  Type EIF or Legacy EIF or as per Qualifying Fund
  Order or Specialist Fund Order
• 14/05/09 as referred to in paragraph 7(3)(b) of
  the EIF Order (as amended) this only seems to
  be relevant if conversion date is 01/05/09 May
  Day Bank Holiday ?

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Decision Flowchart for EIF Transition
Does the fund wish/need to remain in the Isle of
Man ?
Yes
No
Consider redomiciliation to another jurisidction
prior to midnight on 01/11/08
Is the fund an open-ended Investment company ?
Yes
No
Consider whether conversion to closed-ended
structure is commercially/legally possible
See overleaf
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Decision Flowchart for EIF Transition
Does the fund need to continue to
accept additional or new investments ?
Yes
No
Consider Closed EIF status and closing to
investment prior to midnight on 01/11/08
Has the fund always had a minimum initial
investment of at least US100K ?
Yes
No
Can the fund continue to work if subject to
specialist Investor requirements ?
Yes
No
See overleaf
Consider conversion to Specialist Fund status
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Decision Flowchart for EIF Transition
Can the fund operate with a minimum investment of
US100K in future ?
Yes
No
Can the fund continue to work if subject to
specialist Investor requirements ?
Does the fund have an exempt manager staying in
situ or is an IOM resident director problematic?
No
Yes
Yes
Consider conversion to Legacy EIF status
Consider conversion to Qualifying Type EIF
Consider conversion to Qualifying Fund
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Because you can
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Because you can
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Historic Regulatory Issues

• Lack of clarity of roles of Manager and
  Administrator
• Ability foreign funds to be established as
  Experienced Investor Funds (EIF)
• Unsatisfactory due diligence on functionaries
• Promotion of EIFs to unsuitable investors

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Historic Regulatory Issues

• Concern that policyholders of PPBs unaware of
  higher risks of an EIF
• Reputational risk to the Isle of Man
• Lack of clarity re responsibility for the
  accuracy of Offer Documents
• No set appointment criteria for fund Auditors
• Absence of processes around the late issue of
  Accounts

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Changes resulting from FRG

• Introduction of Schemes Bill
• Introduction of Regulated Promoter
• Relaxation licensing of Asset Managers
• Introduction of Specialist Fund (presentation
  Simon)
• Introduction of Qualifying Fund (presentation
  Simon)
• Changes to EIFs (presentation Simon)

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Schemes Bill

• Clear definitions of Governing Body, Manager,
  Administrator, Custodian, Promoter, Asset Manager
  (Key Parties)
• Clarity on key duties and responsibilities of Key
  Parties
• Fund Manager and Fund Administrator to notify
  Commission on matters which may have a material
  adverse effect on a fund
• Fund Auditor to notify Commission of any matter
  which may be of material significance

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Schemes Bill

• In addition to the existing powers to
• require a fund to suspend dealing
• require a fund to be wound up
• Additional powers to
• appoint reporting accountant or administrator
• assume control of the business
• require an Auditor at any time

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Fund Changes

• No new EIFs to be established
• New funds established as SIFs/QIFs must be Isle
  of Man domiciled
• Requirement to have an Asset Manager/Investment
  Adviser (Governing Body to determine suitability)
• Requirement for an independent (non executive)
  director and an Isle of Man resident director
  (can be same person)

53
Fund Changes

• Responsibility of Governing Body (and, where
  applicable, Manager) to ensure Offer documents
  include all material information
• Responsibility statement to be completed by
  Governing Body at launch and when changes made to
  a fund
• Annual compliance statement to be completed by
  Governing Body

54
Fund Changes

• More robust investor entrant criteria
• More robust health warnings re unregulated
  nature of the fund
• Offer documents no longer required to be
  submitted to the Commission
• Offer documents replaced with Notification forms
  (to be submitted post launch) detailing specific
  information relating to the fund

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Fund Changes

• Fund Auditor to be qualified auditor who must
  be Isle of Man Auditor and PI requirements of 20
  million
• Fund Accounts to be issued no later than 6 months
  after financial year end
• Notification procedure for late Accounts and
  where Accounts are qualified

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Fund Changes

• Ability to appoint Overseas Administrator
  (certain fund types) in Acceptable Jurisdiction
• New classes of 3(b) licence for Associated Asset
  Managers and Specialist Asset Managers
• New class of 1 (c) licence for Promoter

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Acceptable Jurisdictions

• Minimum criteria applied by the Commission when
  assessing whether a jurisdiction is an acceptable
  jurisdiction
• Is there a memorandum of understanding between
  the Commission and its equivalent regulatory body
  providing, inter alia, for mutual assistance and
  cooperation in relation to fund
  management/administration and associated
  activities?
• Are licenceholders in that jurisdiction licensed
  on the basis of a Fit and Proper assessment?
• Are there adequate arrangements in place in the
  jurisdiction for the supervision of its
  licenceholders?
• Are there adequate powers for enforcement and
  remedial action at the disposal of the regulatory
  body (equivalent to those of the Commission)?

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Acceptable Jurisdictions

• Additional matters taken into consideration by
  the Commission
• any relevant international assessment reports
  which consider the jurisdictions compliance with
  international regulatory standards and
  cooperation principles (including those of the
  International Monetary Fund)
• participation in international cooperation
  initiatives (such as the IOSCO Multi-lateral
  Memorandum of Understanding)
• any experience of regulatory cooperation with
  that jurisdiction.

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Governing Body Responsibilities

• Responsible for ensuring
• the requirements in the Order are complied with
• the offering document and relevant constitutional
  documents of the fund comply with the
  requirements of the Act and Order
• the fund is and continues to be managed and
  operated in accordance with the funds
  constitutional documents and offering document
• the offering document of the fund is accurate and
  up to date (and is kept up to date)
• Compliance declaration to Commission within 6
  months of the year end
• the responsibilities imposed upon the Manager (or
  Administrator) are discharged and
• for Qualifying Funds, a minimum subscription
  amount appropriate to the fund is determined with
  the Manager.

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Manager/Administrator Responsibilities

• Must be a licenceholder and has the following
  responsibilities
• notify the Commission if the fund has not been
  managed and operated in accordance with the
  funds constitutional and offering documents
  (Qualifying Funds)
• notify the Commission where a member of the
  Governing Body of the fund is removed, resigns or
  is not reappointed (with reasons)
• satisfy itself that each investor in the fund has
  certified they are a Qualifying/Specialist
  investor
• send launch/alteration notifications to the
  Commission

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Manager/Administrator responsibilities

• CONTINUED
• send compliance declaration to the Commission
• send quarterly statistics to the Commission
• report to the Commission in certain circumstances
  including where an audit report is qualified or
  accounts are late, or an auditor is removed,
  resigns or is not reappointed
• determine a minimum subscription with the
  Governing Body (qualifying funds).

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Regulated Promoter - Qualifying Funds (
Qualifying EIFs)

• SUMMARY
• Promoter responsible for Offer document and
  associated marketing material
• Promoter responsible for assessing and appointing
  Acceptable Financial Advisers
• Regulated Promoter must ensure that the
  Acceptable Financial Adviser has
• necessary Regulatory permissions
• can demonstrate competence (experience and
  qualifications)
• can demonstrate has processes and controls to
  determine suitability

63
Roles/responsibilities of a Promoter

• The vetting and approval of fund offer documents
  and advertisements
• Checking the experience and competence of the IFA
  who will be advising the client
• Completing due diligence on IFAs (including
  checks on regulatory permissions and licences)
• Satisfy itself on the distribution process of the
  IFAs

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Roles/responsibilities of a Promoter

• Assess the IFAs processes, controls and investor
  records
• Issue Terms of Business to the IFA (identifying
  them as Acceptable Financial Advisers)
• Responsibility for mentoring and ongoing
  suitability checks on IFAs
• Ensuring that Insurance Companies are complying
  with the investor disclaimers

65
Acceptable Financial Adviser - Qualifying Fund (
Qualifying EIFs)

• Acceptable Financial Adviser must certify that
  the investor qualifies as a qualifying investor
  and that the fund is suitable for investment

66
Roles/responsibilities of Acceptable Financial
Adviser

• Undertaking KYC on investors
• Ensuring that the investor meets the experienced
  investor criteria
• Establishing a process to determine suitability
  of investment for clients
• Holding sufficient records which can be made
  available to the Promoter, when required

67
Licensing of Promoters

• Category 1(c) covers acting as Promoter to
  funds that require the appointment of a Promoter
  i.e. Qualifying Fund and Qualifying EIF
• Must have a real presence cannot be a managed
  operation
• Whilst no 4 eyes requirement, will generally need
  both an MD and a company secretary, one of whom
  may be MLRO a locum may be required
• Compliance with advertising code required

68
Licensing Promoters

• No corporate track record required, but any
  individuals who advise customers must be
  qualified and a key individual is expected to
  have at least 3 years experience
• Minimum net tangible assets of 10,000
• No expenditure based requirement
• Independent Professional Indemnity Insurance
  required
• No access to, or control of, clients money is
  permitted

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Promoter Activities

• In terms of the Qualifying Fund which will be
  distributed by the Promoter, the Commission is
  interested in the marketing or promotional
  campaign for the fund, which may include
• Marketing material that will be used
• Duration and style of the marketing campaign
• Expected number of IFAs involved in the
  promotion
• Expected monies planned to be raised at
  launch/thereafter
• Expected number of investors

70
Asset Managers

• Category 3(b) licences covering alternative asset
  management services to specialist-type funds
• Stream-lined licensing process designed to
  encourage new businesses to come to the Isle of
  Man
• Two sub-categories covered by the process
• Associated asset managers part of a regulated
  group or under common control with a regulated
  entity
• Specialist asset managers independent i.e. not
  part of a regulated group etc, but business
  proposed to be confined to specialist-type funds

71
Associated Asset Managers

• Must be part of a group with an entity regulated
  in an acceptable jurisdiction or under common
  control with such an entity
• No corporate track record required experience
  of individuals in other spheres will count
• Managed manager option is available
• Otherwise, real presence is required with one
  IOM-based 4-eyes being obligatory
• IOM resident director required

72
Associated Asset Managers

• No requirements for quarterly financial returns
• No minimum net tangible assets requirement or
  expenditure based requirement, but ongoing
  solvency requirement applies
• Group PII cover is acceptable
• Cannot hold clients money or investments
• Licence restricted to managing specialist-type
  funds

73
Specialist Asset Managers

• Similar to existing licences, but difference in
  approach because activities restricted
• No corporate track record required experience
  of individuals in other spheres will count
• Real presence is required but more flexible
  approach to staffing and one IOM-based 4-eyes is
  obligatory
• IOM resident director required
• Normal financial and reporting requirements apply
• Stand-alone PII required
• Licence restricted to managing specialist-type
  funds

74
Managed Managers

• Expected that changes to EIF regime may inspire
  more managed manager applications in respect of
  Qualifying Funds and Qualifying Type EIFs
• Normal FSC category 3(b) licensing policy applies
  in these cases
• Detailed consideration of licensed entity and
  out-sourced management arrangements
• Managed associated asset managers considered
  above
• Category 4 licence holder can provide services to
  a managed manager
• Category 3(b) licence holders may provide
  services to a managed manager if FSC satisfied it
  can demonstrate competence and experience

75
State of the Nation

• Increase in Asset Manager Applications
• Increase in Fund Manager/Fund Administrator
  Applications
• First conversions to QIF/SIF
• New SIFs/QIFs

76
State of the Nation

• Points to remember
• Investment Business Licences require to be
  updated to manage/administer SIFs/QIFs
• No offer documents require to be submitted to the
  Commission for SIFs/QIFs
• Promoter required for all QIFs/Qualifying EIFs

77
Because you can