Reporting obligations under the Alternative Investment Fund Managers Directive (AIFMD), known as Annex IV, will entail significant work for fund managers that are domiciled in Europe or market their funds to European investors.
“Essentially, all managers that have a nexus to the EU will have to provide or prepare Annex IV reporting,” Dermot Mockler, group head of regulatory affairs, compliance & anti money laundering at TMF Custom House Global Fund Services, told Markets Media. “It is a significant amount of regulatory reporting data including information on the manager, information on the fund and risk data, a lot of which will reside with the manager but not with the administrator.”
The U.K. Financial Conduct Authority and the European Securities and Markets Authority with the past week have published updates to their guidance on Annex IV reporting.
The FCA published an updated version of the its official Question & Answers document on AIFMD Annex IV Transparency Reporting, providing further clarity on key issues such as who, what and when to report under AIFMD.
The FCA said that funds must provide required transparency information in accordance with the pro-forma reporting templates set out in Annex IV of the AIFMD. The FCA will use two reports to collect transparency information which must be used by all AIFMs: a Manager Reports, used to provide AIFM-specific information, and a Fund Transparency Report, used to provide AIF-specific information.
As the first AIFMD reporting filing deadline approaches, AIFMs should now be focusing their efforts on becoming AIFMD-compliant and meeting the Annex IV Transparency Reporting requirements.
“Bearing in mind the complexity of the project which requires identifying and cleansing a vast amount of data from multiple systems and sources, firms should be developing their internal processes to ensure they are ready to submit their first AIFMD reports on time,” Ani Nacheva, marketing coordinator at Arkk Solutions, a provider of regulatory reporting systems, said in a blog posting,
TMF Custom House is preparing to launch a service related to the AIFMD Directive where it will assist client managers with Annex IV Reporting. The company is engaging with service providers with a view to rolling out a product in the 4th quarter 2014.
“Depending on the size of the funds under management and the domiciles, then reporting needs to be done on quarterly, semi-annually or annually, but every fund or every manager that has a nexus to the EU has to prepare and provide Annex IV reporting or regulatory reporting to one or more regulatory bodies around the EU,” Mockler said. “It's very like Form PF in terms of the numbers and types of data.”
Featured image via leungchopa/Dollar Photo Club
