With AIFMD II now transposed into Maltese law, fund promoters, asset managers and family offices have a fresh set of tools at their disposal for building loan origination and private credit vehicles domiciled in Malta.
Corporate lending by Alternative Investment Funds is now expressly catered for under the revised framework, contingent on meeting the relevant AIFMD II conditions. Separately, the MFSA has updated the Notified Alternative Investment Fund (NAIF) regime specifically to bring loan origination within its scope. One boundary the regulator has drawn clearly: NAIFs cannot extend credit to consumers based in Malta.
The case for structuring in Malta
Property developers and other corporates stand to gain a domestic source of financing through a Maltese loan origination fund, while the same structure gives professional investors and family offices a regulated channel into private credit markets.
Passporting is where the structure earns its keep. A NAIF under the management of an authorised EU AIFM can be distributed to professional investors right across the bloc via the AIFMD marketing passport, subject to the usual notification steps.
Optional ELTIF status, not mandatory
Setting up a loan origination fund under Malta's AIF regime does not automatically mean pursuing European Long-Term Investment Fund (ELTIF) authorisation. The two are separable.
Where a promoter's ambitions stretch to retail distribution, however, ELTIF status becomes a more relevant consideration. It opens the fund to eligible retail investors across the EU, broadening the pool well beyond the professional-investor base.
Put together, these developments give Malta a distinctive role: a meeting point for private capital chasing alternative returns and businesses hunting for financing outside the traditional banking channel. Firms such as CC Fund Services (Malta) Ltd. are positioned to support fund promoters and asset managers through the establishment and ongoing administration of these loan origination and private credit structures.
CC Fund Services (Malta) Ltd. (CCFS) is a Recognised Fund Administrator and is authorised to act as a Company Service Provider by the Malta Financial Services Authority (MFSA). CCFS is also approved to act as a Due Diligence Service Provider. CCFS is a member of the Malta Asset Servicing Association (MASA).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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