Performance reference period for the hurdle rate model

[ESMA 34-43-392 UCITS Q&A, Section 11, 7a] & [ESMA 34-32-352 AIFMD Q&A, Section 15, 9] Yes, as paragraph 42 of the guidelines [1] clarifies that the only exception to the application of the 5-year performance reference period is “ the fulcrum fee model and other models which provide for a symmetrical fee structure ”. [1] Paragraph 42 of the Guidelines states that “The performance reference period should not apply to the fulcrum fee model and other models which provide for a symmetrical fee structure, as in these models the level of the performance fee increases or decreases proportionately with the investment performance of the fund”.