Feedback on Fund Fees Consultation No.3 2023

Summary

This is the JFSC's feedback paper on Consultation No.3 2023, which proposed increasing fees for a range of Jersey fund structures by 2% above RPI. After considering the single response received (from the Jersey Funds Association), the JFSC decided not to apply the additional 2% and instead increased fees by RPI alone (a total of 12.7%). The finalised Fees Notices are attached as appendices and took effect from 1 July 2023.

• Scope of fee increase: A 12.7% increase (RPI only, not RPI+2%) applies to AIF, CIF, JPF, CoBO, QSMA and FSB fee rates for the period 1 July 2023 to 30 June 2024.
• Fees Notices updated: Appendices B to F contain the final AIF/AIFSB, CIF, CoBO, FSB and QSMA Fees Notices, including application fees, annual fees, new pool fees, and QSMA charging-period fee scales.
• Invoicing and payment: Firms are notified via myJFSC when an invoice is ready; payment is due 30 days from the invoice date.
• Late payment: Late fees may be charged as set out in the relevant Fees Notice (e.g. a 5% late payment fee on unpaid amounts under the QSMA Notice); firms in difficulty should contact their supervisor before the due date.
• Future review: The JFSC noted further consultation is expected on the structure of future fees, following discussions with the JFA.

The document is primarily a consultation feedback and fee-setting notice rather than a new standalone obligation; the substantive ongoing duties are the payment obligations set out in the attached Fees Notices (application fees, annual fees, and timely payment of invoices).

Key obligations

• Pay fund-related fees (AIF, CIF, JPF, CoBO, FSB, QSMA) at the revised rates (RPI increase, 12.7% total) effective from 1 July 2023, as set out in the applicable Fees Notice.
• Pay invoices for fees within 30 days of the invoice date once notified via myJFSC.
• Where a late payment fee applies under a specific Fees Notice (e.g. QSMA), pay an additional 5% of the unpaid principal if not paid by the due date, escalating monthly.
• Permit holders under the CIF regime must pay the annual fee due on 31 July each year based on pools of assets held on 1 July.
• Firms experiencing payment difficulties must contact their supervisor in advance of the due date.

Applies to

Alternative Investment Funds (AIF), AIF Services Business (AIFSB), Collective Investment Funds (CIF), Jersey Private Funds (JPF), CoBO-regulated entities, Fund Services Business (FSB) registrants, Qualifying Segregated Managed Account (QSMA) operators, Permit holders and certificate holders under the Collective Investment Funds (Jersey) Law 1988, Registered persons carrying on fund services business

Deadlines

• 1 July 2023: Revised fee rates (RPI increase of 12.7%) for AIF, CIF, JPF, CoBO, FSB and QSMA fees become effective, covering the period 1 July 2023 to 30 June 2024.
• 30 days from the date of the invoice: Due date for payment of fees once a firm receives an invoice notification via myJFSC.
• 31 July each year: Due date for the CIF annual permit holder fee based on pools of assets held on 1 July.
• 24 June 2023: Closing date of the consultation period (historical, informational only).