Articles

How much return does AIFMD II cost an open-ended credit fund?

The leverage cap is the obvious cost of running a loan-originating AIF open-ended, and the smallest part of it.

On illustrative figures, structuring a loan-originating fund as open-ended under AIFMD II costs about 1.8 points of annual return on NAV: 8.45 per cent against 10.25 per cent for the same loans in a closed-ended fund. Only 0.625 of a point, 35 per cent of the gap, comes from the 175 per cent leverage cap itself. The rest is the headroom an open-ended fund must keep below the cap and the cash it must hold to meet redemptions.

Worked in full in The AIFMD II Handbook by Julian R. Sterling, with every figure reproduced in a free workbook.See the book on Amazon →

Directive (EU) 2024/927, AIFMD II, sets two leverage caps for loan-originating AIFs, measured under the commitment method as exposure divided by net asset value: 175 per cent if the fund is open-ended and 300 per cent if it is closed-ended. It also requires loan-originating AIFs to be closed-ended unless the AIFM can show its competent authority that the fund's liquidity risk management is compatible with its investment strategy and redemption policy. A manager choosing between the two structures needs to know what the open-ended route costs investors in return. The cap is the obvious answer and the smallest part of it.

The assumptions

The same loan book in two structures, illustrative figures, per 100 of NAV
InputOpen-endedClosed-ended
Leverage cap (commitment method)175%300%
Leverage actually run150%200%
Cash held for redemptions, % of NAV10%0%
Loan yield10.0%10.0%
Expected credit loss a year1.0%1.0%
Cost of borrowing6.5%6.5%
Yield on cash3.5%n/a
Management fee, % of NAV1.25%1.25%

The open-ended fund runs at 150 per cent, 25 points under its cap, because a fund at the cap breaches it after a modest markdown, as shown in how much markdown breaches the 175 per cent cap. Its exposure is at most 150 per cent however the cash is treated. The closed-ended fund runs at 200 per cent, well inside 300 per cent, which is closer to what its lenders will offer than to what the directive allows.

The calculation, step by step

Step 1: the balance sheet per unit of NAV

Loans = leverage − cash. Borrowing = leverage − 100%.

Open-ended: loans 1.40, cash 0.10, borrowing 0.50. Closed-ended: loans 2.00, borrowing 1.00.

Step 2: return on NAV

Return = loans × (loan yield − loss) + cash × cash yield − borrowing × cost of debt − fee

Open-ended: 12.60 + 0.35 − 3.25 − 1.25 = 8.45%.

Closed-ended: 18.00 − 6.50 − 1.25 = 10.25%.

Excel, with leverage in B1, cash in B2: =(B1-B2)*(10%-1%)+B2*3.5%-(B1-1)*6.5%-1.25%

Step 3: split the gap

Each 25 points of leverage is worth 0.25 × (9.0% − 6.5%) = 0.625 of a point. Each point of NAV held in cash instead of loans gives up 9.0% − 3.5% = 5.5%.

The result

Where the 1.80 points go
StepReturn on NAVCost
Closed-ended at 200%10.25%
Held to the open-ended cap, 175%9.625%0.625
Headroom below the cap, 150%9.000%0.625
Cash sleeve of 10% of NAV8.45%0.55
Open-ended fund8.45%1.80

The statutory cap accounts for 35 per cent of the gap. The headroom costs as much again, and it is a choice forced by the cap rather than written in it: a fund that ran at 175 per cent would breach on the first markdown. The cash sleeve is not an AIFMD II leverage effect at all. An open-ended fund needs liquidity to pay redemptions, and must also select at least two liquidity management tools from the directive's Annex V list, whatever its leverage.

The closed-ended fund could in principle run at 300 per cent and earn 12.75 per cent on these assumptions, with 2.00 of borrowing per unit of NAV. Lenders to a direct lending book are usually more conservative than that, which is why, on figures like these, the lenders' terms bind the closed-ended fund before the 300 per cent cap does, while the 175 per cent cap binds the open-ended one.

What if borrowing costs or losses change?

Return on NAV, open-ended at 150% with 10% cash vs closed-ended at 200%
ScenarioOpen-endedClosed-endedGap
Cost of debt 5.5%8.95%11.25%2.30
Cost of debt 6.5% (base)8.45%10.25%1.80
Cost of debt 7.5%7.95%9.25%1.30
Credit loss 3.0%5.65%6.25%0.60
Credit loss 5.0%2.85%2.25%−0.60

The gap is the price of leverage, so it shrinks as the spread between net loan yield and borrowing cost narrows. At a 5.0 per cent loss rate the net loan yield falls to 5.0 per cent, below the cost of debt, and the less levered open-ended fund does better by 0.60 of a point. The open-ended structure gives up return in the base case and loses less in a bad credit year.

The common mistake

Pricing the open-ended structure as "175 instead of 300". On these figures that comparison would suggest a cost of 3.125 points, the 125 points of leverage between the caps at 2.5 points of spread, when the realistic gap is 1.80, and only 0.625 of that is the cap. The two numbers that decide the case are the leverage the closed-ended fund can actually borrow and the size of the open-ended fund's liquidity sleeve. Before that, check that the fund is loan-originating at all, under the test in when a fund is a loan-originating AIF.

Takeaway

The liquidity side of the same trade-off, Fund IV's reverse stress level with its facility, is computed in the free workbook for this book.

Questions readers ask

What are the AIFMD II leverage limits for loan-originating funds?

Directive (EU) 2024/927 caps leverage of a loan-originating AIF at 175 per cent of NAV if open-ended and 300 per cent if closed-ended, under the commitment method. In practice the open-ended fund runs below its cap: in the illustration at 150 per cent, which with a 10 per cent cash sleeve leaves 1.40 of loans and 0.50 of borrowing per unit of NAV.

Can a loan-originating AIF be open-ended under AIFMD II?

Yes, but closed-ended is the default. An open-ended structure is allowed where the AIFM can demonstrate to its competent authority that the liquidity risk management system is compatible with the investment strategy and redemption policy. On illustrative figures the choice costs 1.80 points of annual return on NAV, 8.45 against 10.25 per cent.

Does more leverage always make the closed-ended fund return more?

Only while the net loan yield exceeds the cost of debt. With a 5.0 per cent annual credit loss the net yield in the illustration falls to 5.0 per cent against 6.5 per cent borrowing, and the open-ended fund at 150 per cent earns 2.85 per cent against 2.25 for the closed-ended fund at 200 per cent.

Read the whole case

This article is one calculation from The AIFMD II Handbook. The book takes the same case from first principles to the decision, chapter by chapter, and every figure it prints is a live formula in the free companion workbooks.

Get the book on Amazon →Free companion files

Also on Amazon UK · Amazon Germany · Amazon France · Amazon Canada

Also on this site

Reading guide: regulation, compliance and banking → · All 1682 articles →

If this book helped, or didn’t, a few lines on Amazon are worth more than they look: they are what the next reader goes on. Write a review. The workbook stays free either way.