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At Long Last—BaFin Issues New Guidance to German Pension Funds on Eligibility of Investment Products
15 December 2017
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On 12 December 2017, the German Federal Financial Authority (“BaFin”) issued a long-awaited Circular providing guidance on the conditions under which German pension funds and small insurance companies may invest in financial products.
While the Circular includes some improvements and clarifications for investors in private equity funds, it does not include any new guidance regarding debt funds and real estate funds.
Borrowing at the private equity fund level is now permitted to the extent it has the purpose of bridging capital calls.
The new Circular explicitly allows German open-ended special funds to invest in closed-ended private equity funds that comply with the Investment Ordinance.
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