6. Do Fund Managers of Funds or Syndicates need a license?

A Fund Manager is an individual  responsible for the implementing Fund’s (or Syndicate’s) investment strategy and managing its investments.

The role of a Fund Manager is performed by a General Partner (in Funds) and a Managing Member (in Syndicates) whose powers and functions are regulated by corporate documents (LLC Agreement or LPA). An admission of investors, consent to the transfer of interest by an investor, representation of a Fund (or a Syndicate) with ‘outsiders’ (service providers, portfolio companies, government authorities) and others may be included.

However, since the primary role of Fund Managers is to manage investments, they are covered by a definition of Investment Advisor and should be registered, unless any exemption applies to them (see Question 7).