Article 3
Criteria to determine the minimum holding period referred to in Article 18(2), first subparagraph, point (a), of Regulation (EU) 2015/760
The manager of an ELTIF that chooses to determine a minimum holding period as referred to in Article 18(2), first subparagraph, point (a), of Regulation (EU) 2015/760 shall consider all of the following:
the long-term nature and investment strategy of the ELTIF;
the underlying asset classes of the ELTIF, their liquidity profile, and their position in their life-cycle;
the ELTIF’s investment policy, and the extent to which the ELTIF takes part in the investment policy and governance of the underlying assets in which the ELTIF invests;
the investor base of the ELTIF and:
where the ELTIF is marketed to retail investors, the expected aggregate concentration of retail investors;
the information on the degree of concentration of the ownership of the professional investors in the ELTIF, where available;
the liquidity profile of the ELTIF;
the procedures for the valuation of the ELTIF’s assets, and the time required to produce a reliable, sound, and up-to-date (based on the most recent data) valuation;
the extent to which the ELTIF lends or borrows cash, grants loans, or enters into securities lending, securities borrowing, repurchase transactions, or any other agreement which has an equivalent economic effect and poses similar risks;
the portfolio composition and diversification of the ELTIF;
the average and mean length of life, where applicable, of the assets of the portfolio of the ELTIF;
the duration and the characteristics of the life-cycle of the ELTIF and the ELTIF’s redemption policy;
the timeframe for the investment phase of the investment strategy of the ELTIF;
whether the minimum holding period, where applicable, is consistent and commensurate with the time necessary to complete the investment of the ELTIF’s capital contributions, and in particular:
whether that minimum holding period covers at least the initial investment phase of the ELTIF;
unless duly justified by the manager of the ELTIF, whether the minimum holding period lasts at least until the ELTIF’s aggregate capital contributions have been invested.