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Malta's implementation of AIFMD II creates new opportunities for asset managers, fund promoters and family offices considering loan origination and private credit funds in the jurisdiction.
Under the revised framework, Alternative Investment Funds may originate loans to corporate borrowers, subject to the applicable AIFMD II requirements. The MFSA has also amended Malta's Notified Alternative Investment Fund (NAIF) framework to address loan origination. The restriction specifically highlighted by the MFSA concerns lending to consumers in Malta.
Why establish a Loan Origination Fund in Malta?
A Malta loan origination fund can provide financing to corporate borrowers, including Maltese property development companies, while giving professional investors and family offices access to private credit opportunities through a regulated fund structure.
A particularly attractive feature is EU passporting. A Malta NAIF managed by an authorised EU AIFM can benefit from the AIFMD marketing passport, allowing the fund to be marketed to professional investors across the EU, subject to the applicable notification requirements.
Does a Loan Origination Fund need to be an ELTIF?
Not necessarily. A loan origination strategy may be established within Malta's AIF framework without automatically requiring European Long-Term Investment Fund (ELTIF) status. However, ELTIF authorisation may be attractive where a promoter wants to access a broader investor base, including eligible retail investors across Europe.
This creates an interesting proposition for Malta, connecting private capital seeking alternative investment opportunities with businesses looking for alternative sources of finance. Firms such as CC Fund Services (Malta) Ltd. are positioned to support asset managers and fund promoters considering the establishment and ongoing administration of loan origination and private credit fund structures in Malta.
CC Fund Services (Malta) Ltd. (CCFS) is a Recognised Fund Administrator and, is authorised to act as a Company Service Provider by the Malta Financial Services Authority (MFSA). CCFS is also approved to act as a Due Diligence Service Provider. CCFS is a member of the Malta Asset Servicing Association (MASA).