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New € 100k thresholds for AIF distributed to some Italian non-professional investors

he MEF Decree no 19/2022, entered into force on March 30, 2022, has introduced an additional class of Non Professional Investors in Reserved AIF, by adding two new sub-paragraph to the above-mentioned article 14, para 2, of the MEF Decree no 30/2015.
It is important to note that the MEF Decree no 19/2022 didn’t lower the Euro 500K threshold for being treated as professional investors for the purpose of the marketing of AIFs, but introduced a new class of Non Professional Investors in Reserved AIF that can invest Euro 100K provided that this is done within the scope of an investment service that imply a prior assessment of suitability – i.e., non-discretionary investment advice or management of investment portfolios on a discretionary basis – and that the 10% threshold is complied with in case of investments within the scope of investment advisory services.

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