This Alert is provided for information purposes about AIFMD Reporting and will be of particular relevance to Alternative Investment Fund Managers (AIFMs) including non-EEA AIFMs marketing in the UK.
The FCA has published information/guidance on its website on AIFMD Annex IV reporting (‘transparency reporting’), being the reporting covered in SUP 16.18.
There are two separate publications: one for UK AIFMs, including small registered AIFMs, and one for non-EEA AIFMs marketing in the UK. Links to them, and to the two new AIFMD reporting templates, are provided below.
Points to note in respect of UK AIFMs (numbers in brackets refer to relevant paragraph of FCA information document):
- Two reports must be used to provide the required information. The AIF001 provides AIFM-specific information whilst AIF002 provides AIF-specific information (9)
- An FCA issued Product Reference Number (PRN) must be used to identify each AIF (10)
- Note that the FCA has not yet issued any PRNs [or FRNs to small registered UK AIFMs] (11) – but also see (36)
- Alternative identification codes e.g. LEIs are also required and firms are encouraged to obtain ‘as many as possible’ (13)
- Information on the reporting of fund-of-funds, feeder AIFs and umbrella structures is addressed (14) – (20)
- Frequency and submission dates, including the 15 day extension for fund-of-funds, is addressed (21) – (28)
- First report due (‘following quarter rule’) is addressed (29) – (33)
- GABRIEL development to enable submission of AIF001 & AIF002 will commence 20 October and PRNs will be issued (34) – (36)
- Once live the FCA will only accept AIF001 & AIF002 reports via GABRIEL (37)
- The rollout process is addressed (38) – (40)
- Firms are required to verify that AIF001 & AIF002 reporting functionality is correct; actions if a firm disagrees with frequency is also addressed (41) – (42)
- GABRIEL submission can be by: (a) online form i.e. manual keying-in; (b) file upload via webpage (XML); or (c) direct i.e. system-to-system (44)
- Note that (a) entering AIF001 & AIF002 reports and (b) submission of those reports involves two separate actions and both must be completed (47)
- Technical information for those using XML upload or system-to-system is addressed (50)
- GABRIEL support is offered by the FCA (43) & (51)
- Submissions will be monitored and failure to meeting reporting submission dates (a reminder may be sent) may involve an administration fee of £250 or even enforcement action (52) – (55)
- AIFMs required to complete a quarterly report for the period to 30 September 2014 must contact the FCA as soon as possible (57) – (59)
- Useful links are provided (60) – (61)
Complyport clients should contact their usual relationship manager if they have any questions about AIFMD Reporting.
