On June 3, 2015, the Japanese government promulgated an amendment to the Financial Instruments and Exchange Act (FIEA). One of the main impacts of this amendment is the enhancement of restrictions on activities in relation to partnership-type funds in Japan.
In principle, it is necessary to obtain a license under the FIEA to conduct marketing and investment management activities for investment funds. However, the license is not required for activities in relation to investment funds in the form of certain partnerships, for example, if one or more Qualified Institutional Investors invests in the fund and certain other requirements are met, as well as if the filing of a simple notification known as Form 20 is made (Form 20 Exemption). Entities under this exemption are not treated as financial instruments business firms and more than 3,000 Japanese and non-Japanese entities have been utilizing this exemption.