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MS experts meeting: DA for ESIF financial instruments 12 December 2013 Regio.B3
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Changes in the Delegated Act
Adaptation to the latest CPR numbering and wording (e.g. bodies implementing financial instruments vs. financial intermediaries) Legal drafting further streamlined References to the EAFRD and the EMFF reviewed Management costs and fees ceilings reviewed following MS comments (AT, DE, LT, CZ) Redundancies: 3.8 (capitalisation of interest rates and guarantee fees subsidies) that escrow account and for investments in the eligibility period (Role, liabilities and responsibilities) that need to comply with the law Order: a singled out 3.5. on rules for certain products, i.e. guarantees Further specified requirements: 3.9 (criteria for determining management costs and fees) and 3.10 (ceilings for management costs and fees to be paid after eligibility period for micro-credit and equity-based instruments)
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Changes in the DA: Management costs and fees
LIMIT Base Performance Fund of Funds 6.00% First 2 Ys % 0.50% Following 0.50% Loan fund 7.00% 1.00% Guarantee fund 10.00% 1.50% Equity fund 20.00% First 2 Y % 2.50% Following 1.00% Micro credit Others * For equity, base remuneration linked to amounts committed to clarify whether/why the individual final recipient and not investment 3.6.3.f.ii – to align as close as possible with Article 132(1) of the CPR ("Availability of documents")
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Management costs and fees: Key points to keep in mind
The ceilings do not apply if an open competitive selection procedure proves that higher ceilings are necessary (Article of the DA). Linking remuneration to committed amounts would not be performance-based and in contradiction with Article 42.5 of the CPR. Equity is the only duly justified case. The exact remuneration method is to be agreed between the MAs and bodies implementing financial instruments. The DA sets only the requirements for eligible expenditure (here performance=disbursement). Additional MCF can be paid from other sources, including those from repayments in line with Article 44: e.g. once the first loans are repaid the financial intermediary can use the resources repaid to cover management costs and fees. For these there are no limits in the Regulation.
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Thank you for your attention! Time for questions & answers
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