PIF Manager
Milo / 10.08.2022
A PIF is either (a) a self-managed entity that either (a1) has an Investment Committee that makes the investment decisions and executes them or (a2) appoints an external manager, such as Abalone, to execute trades on behalf of the self-managed entity's investment committee, or it is a (b) a fund that is not self-managed and that appoints a de-minimis AIFM (Abalone cannot offer this service, as we have a full AIFM licence) to make investment decisions on behalf of the fund. To offer service (a2) for a crypto fund we would need to understand what is the trade execution job involved (how many trades per day, what virtual assets we are talking about, exchanges, technology required, etc.) to check if feasible with our current human resources/infrastructure, but assuming we could offer the service and considering your rebate as introducer, we would not want to do it for less than 50K a year as an updated pricing. If you could also review the bit where you talk about the AIF ManCo in lilght of what I said above, indeed Abalone would not be acting as an AIFM.
Milo / 12.8.2022
A PIF that exceeds 100mm must become a fully fledged AIF/NAIF (upgrade process must be done with the MFSA), appoint a depositary and a Full AIFM.
The TER of a PIF is similar to the one of an AIF/NAIF, even if it does not have a depositary and therefore can save from such cost, it needs to have an internal investment committee that normally makes up for the saving from the lack of depositary.