With the AIFMD II Directive and the German Fund Risk Limitation Act, which took effect on April 16, 2026, new guidelines apply to lending funds: Leverage caps of 300 percent for closed-end funds and only 175 percent for open-end structures, restricted lending consortia, and a clear commitment to closed-end vehicles, as open-end vehicles pose a risk of maturity mismatches. Lawyer Florian Geuder of King & Spalding praises the fact that the legislature refrained from “gold plating” - the regulation addresses the risks now under discussion without weakening the investment environment.

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