Q3: What support can be given to ELTIFs to encourage their take up? The goal of the ELTIF regime is to provide patient capital to infrastructure projects and SMEs that may otherwise find it difficult to raise capital from traditional sources such as banks. We strongly support the ELTIF regime and believe the following measures would support their uptake: 1) Streamline requirements for cross-border security and recognition But in order for ELTIFs to be a major source of capital, they will need to be able to provide finance on equal terms to bank financing. Measures that could help level the playing field include ensuring the equal treatment of ELTIFs loans and banks providing capital so that a fund in one Member State can originate loans in another. For example, requirements for security and recognition cross-border can be more cumbersome for funds than for banks and could be streamlined. 2) Ensure ELTIFs are attractive to institutional investors Making ELTIFs attractive for institutional investors will be key to the success of the regime. ELTIFs can be a good match for institutional investor’s long term liabilities and it is important that supporting legislation is appropriately calibrated to avoid investors from facing unreasonable barriers to investing. 3) Ensure ELTIFs have access to SME credit data The lack of access to SME credit data also places an ELTIF at a greater disadvantage to banks. Measures to increase the information available on SME’s would aid ELTIFs to make investment decisions (see UK response to Q2). Improvements to SME credit data at individual/portfolio level are important for credit assessment purposes, but also at sectorwide level for benchmarking purposes. 4) The Commission should collate and publish Member States’ infrastructure plans so that they are easily accessible for investors. Since 2010 the UK has published an annual National Infrastructure Plan. The plan covers UK economic infrastructure, and provides a long term project pipeline. The infrastructure pipeline is a forward-looking, bottom up assessment of potential infrastructure investment to 2020 and beyond, which includes large infrastructure projects with a capital value of £50 million and over. The pipeline focuses on economic infrastructure sectors which covers transport; energy; water; flooding; science and innovation; and waste. The National Infrastructure Plan 2014 set out the mix of public and private funding for the pipeline, and expectations for financing the pipeline including detailed information on £79bn of potential project specific investment opportunities. Developing and publishing a National Infrastructure Plan provides certainty for investors on the long term plans of government for funding and financing UK infrastructure, including potential investment opportunities for the private sector. Member States should develop and publish such plans on a regular basis to encourage cross-border infrastructure investment. The Commission should collate and publish Member States’ plans so that they are easily accessible for investors. 5) The EIB should investigate co-investing in ELTIFs The EIB should investigate co-investing in ELTIFs to get them started as an asset class and build them up to size that is visible to mainstream investors, based on the Business Bank ‘investment programme’ commercial template. The purpose of public support would be to grow the market from a low-base, flattening out any lag in investment in ELTIFs resulting from investors’ low awareness of the funds and a short track-record of past performance from these funds.