As a privately owned Asset Manager with a long-term view and mainly conservative institutional clients we intend to launch a new Infrastructure Equity fund.

The Fund would be invested mainly in regulated or “defensive” infrastructure companies as our aim is to give investors the possibility to participate in infrastructure investments with solid and more stable cash flows, solid yield and less cyclicality. For this reason we would not engage in cyclical parts of infrastructure such as mining, oil, cement etc.

As non-listed infrastructure investments are mainly in the focus of bigger players with stronger organisational capacity and broader structures and personnel capabilities, we would like to offer all other insurance companies the possibility to invest in infrastructure with a lower Solvency II equity capital underlying need.

As such we would ask you to outline or define
a)     Whether a listed equity infrastructure fund as described would be eligible for same Solvency II capital adequacy rules as “non-listed” infrastructure investment (which by the way trades at much higher multiples as listed infrastructure equities and is illiquid)
b)    Which level of Solvency II capital ratio would be applicable for a listed equity fund with infrastructure equities (mainly regulated)
c)     Do we have to outline special definitions or criteria in a prospectus
d)    Would this be applicable also to a mutual fund for institutional investors
e)     Could we set up infrastructure equity funds for insurance clients also as single “special” funds with the same regulatory framework of lower SolvencyII requirements

We appreciate your help regarding our aim to set up a defensive infrastructure equities fund (mainly regulated industries : transport, highways, mobile network infrastructure, energy grids ). As such it would be very helpful to get advice on the questions above.