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Key AIC projects. Making the political case for ongoing supportSecuring the best possible VCT rules Seeking increased flexibility of State Aid frameworkResponding to regulatory threatsPositioning VCTs for new rules on distribution of financial products. Political challenges
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1. The AIC’s VCT agenda Guy Rainbird
Public Affairs Director, AIC
3. Political challenges – and opportunities! ‘Austerity’ government and severe cuts inevitable (whoever won!)
Competition from other schemes (e.g. EIS)
Some query if dedicated schemes are the best way to support enterprise, but …
Consensus about contribution of SMEs to job creation and raising the long term economic growth rate
Concern about withdrawal of banks from lending to SME sector
4. Making the political case VCTs represent an existing network of finance and skills
They draw on an otherwise untapped pool of finance
They are cost-effective intervention because of the level of the relief, role of the market and the additional revenues they support
They have a track record of investment in many sectors across the UK
They have created jobs, supported R&D and exports etc
Securing ongoing political support will underpin all other AIC activity
5. Securing the best possible VCT rules Scope of eligible investments for newly raised funds have been altered by demands of securing State Aid approval
AIC has worked closely with officials to ensure European requirements introduced with minimum disruption
Also responded to proposed targeting measures (and delighted that our serious concerns about using SME definition were recognised)
Rules expected in impending Finance Bill
6. Future State Aid developments Rolling back recent State Aid restrictions a key ambition
Success will require changing Commission view on market failure in SME financing
Government invited evidence to argue for increasing:
- employee limit to ‘fewer than’ 100 or 250 full-time employees
- gross assets limit to Ł15m before investment (and Ł16m after)
- annual investment limit to Ł5m per target company, and
- considering the effectiveness of ‘gross assets’ as a proxy for
company size
7. Developing this agenda Secure a continued commitment from HMT to pursue this agenda
Explore what evidence may be required and how the AIC (and its stakeholders) can mobilise data to develop the arguments
First need to persuade the Government to take the case to Europe, then need to convince the Commission
Success unlikely to come overnight
8. The regulatory threat Sea change in political and regulatory attitudes since banking crisis
Europe seeking to tackle systemic risks - but AIFM Directive catches VCTs in the regulatory net!
Proposals undermine the corporate structure (e.g. prevent share issues and undermines role of board)
Also create significant regulatory obligations (e.g. depository, valuation, disclosure, authorisation etc)
9. AIC approach to AIFM Directive Calls for complete exemption fell on deaf ears
Alternative is to apply the obligations to the company (similar to company law, Prospectus and Transparency Directive etc)
Manage compliance burden by targeted derogations which limit obligations for smaller funds
If successful, VCTs will only have to register with competent authority and comply with some disclosure obligations – a major victory!
This outcome depends on current political negotiations
10. Positioning VCTs in evolving market Retail distribution review will reshape financial services market
Will end commission payments by product providers
Independent advisors will have to make recommendations based on a comprehensive analysis of the relevant market
Intermediaries no longer able to focus only on open-ended funds
Investment companies (including VCTs) should be part of the mix
11. Implications of RDR Difficult to predict precise impact of change
Will advisors want to retain the ‘independent’ tag?
Where will VCT investment sit in the analysis of relevant market?
How will platforms respond?
The challenge is to retain and extend advisor recommendations
12. AIC response to RDR Creating an environment which will encourage advisors to consider investment companies – including VCTs
Providing industry statistics
Increasing the quality of investment company data on major consumer sites
13. Improving online information Seven sites now offering high quality investment company data
14. AIC response to RDR Creating an environment which will encourage advisors to consider investment companies – including VCTs
Providing industry statistics
Increasing the quality of investment company data on major consumer sites
Raising PR profile (VCT journalist roundtables, press releases etc)
Lobbying on implementation and providing guidance as required
15. A full agenda AIC will continue its focus on major VCT projects
Highlighting the continued relevance of the VCT scheme
Seeking relaxation of European constraints on policy development
Tackling intrusive regulation (and advising on rules which do apply)
Responding to changing distribution landscape
Keen to hear your views to make sure best outcome for VCTs achieved