The Fund Rulebook (FUNDS) — Abu Dhabi Global Market (FSRA)
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The FUNDS rulebook is the FSRA's operating manual for funds in ADGM. It takes the fund framework set by the Financial Services and Markets Regulations (FSMR) and fills in the detail. That covers the Domestic/Foreign split, the three fund tiers, and the conduct, investment and disclosure rules each tier must follow. The structuring decision it forces is the tier. The choice is a Public Fund (retail, most intensively regulated), an Exempt Fund or a Qualified Investor Fund (professional-only, least regulated). A Domestic Fund must be established or domiciled in ADGM and run by an authorised Fund Manager. Everything else flows from the tier you sit in: spread-of-risk limits, borrowing, valuation, and the REIT and private-credit-fund rules. It is ADGM's counterpart to the DIFC Collective Investment Law across the UAE's two financial free zones.
Scope and the core mechanism
The rulebook works tier-first. Chapter 3 sorts every fund. First comes Domestic vs Foreign. Then comes Public / Exempt / Qualified Investor Fund, "listed in terms of the level of regulation from most intensively regulated to least". The lighter tiers (Exempt, QIF) trade retail access for far fewer rules. This is the classic professional-fund bargain. On top of the tier sit the operative chapters: investment and borrowing requirements (e.g. the Public-Fund spread-of-risk rule at 13.4.2), valuation and pricing, oversight and the specialist regimes (REITs, private credit funds). The full rule-by-rule text is searchable clause-by-clause through the Graph of rules and ask-the-law.
In practice: the tier is the whole game. Pick QIF or Exempt and most of the Public-Fund rulebook simply does not apply to you. But you lose retail distribution. Decide the investor base before anything else, because it fixes the tier, which fixes the rules.
To verify
- Current tier thresholds: confirm the Exempt / Qualified Investor Fund conditions against the current FUNDS rulebook version before relying on them. These are the investor counts, minimum subscription and professional-client tests.
- FSMR interaction: the rulebook is made under the FSMR. Confirm the statutory hooks (fund-management permission, financial-promotion rules) against the current FSMR where they apply.
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