The International Tax Compliance Regulations 2015 (SI 2015/878) came into force in April this year which capture: The OECD’s Common Reporting Standards (CRS) The Directive on Administrative Cooperation (DAC) (2011/16) which implements the CRS in the EU The UK’s FATCA Agreement with the US The effect will be to place [...]
Problems encountered by firms in meeting the demanding Annex IV reporting requirements (SUP 16.18) has led the FCA to issue a further set of Q&As to assist firms and which: Highlight aspects of AIFMD reporting where questions have been misinterpreted by some AIFMS; Identify where AIFMs have provided inconsistent responses [...]
Merill Lynch International (MLI) became the twelfth firm to be fined by the Regulator for a transaction reporting failure – the previous one being Deutsche Bank last August. The Final Notice concerns failings between November 2007 and November 2014, although it does also reference that the firm had been subject [...]
A brief reminder for those firms that are registered with the U.S. Securities and Exchange Commission (“SEC”) that they need to submit an annual updating statement within 90 days of the end of their financial year. With this in mind, those firms whose year end is 31 December 2014 must [...]
It’s now a year (12 February 2014) since the reporting obligation to report to a Trade Repository under EMIR came into force. Firms subject to the EMIR reporting obligation may recall that there were phased reporting windows depending whether the contracts were: i) entered into before 16 August 2012 and [...]
The FCA has updated the Transaction Reporting User Pack (TRUP), the previous version (v 3) was release in March 2012 – see Regulatory Roundup 39. It’s not so much an overhaul of what has been previously stated but is rather a clarification exercise. The majority of changes fall within Chapter [...]
The reporting requirements arising under Article 9 of EMIR (which became obligatory from 12 February this year) are essentially based upon Implementing Regulation 1247/2012 (format and frequency of trade reports) and Delegated Regulation 148/2013 (minimum details to be reported). The three month timeframe in which ESMA had to deliver these [...]
The need for a Legal Entity Identifier (LEI) is most probably associated with reporting under EMIR (see Regulatory Roundup 52) although its use is encouraged elsewhere e.g. AIFMD Reporting (see Regulatory Roundup 59). Some firms may have received an email from the FCA extending the use of an LEI for [...]
One of the obligations introduced by CRD IV was the Country by Country disclosure, for the financial year, arising from Article 89 of the CRD and with the first full disclosure needing to be made on or before 31 December 2015 (initial, limited, disclosure had to be made for the [...]
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 [...]
Those AIFMs that have been authorised under the AIFMD for some time will probably have gotten used to the AIFMD reporting requirements set out in SUP 16.18. However for those AIFMs that have only recently been authorised a reminder that the reporting period is based upon the calendar year and [...]
Now that the transitional period under the AIFMD has passed, more firms will be getting to grips with the obligations of IPRU(INV) 11 which addresses the prudential requirements of both Collective Portfolio Management Firms (CPM) and Collective Portfolio Management Investment Firms (CPMI). As a reminder the former is a full-scope [...]
Regulatory Roundup 53 advised that the EBA had published draft Regulatory Technical Standards (RTS) relating to the calculation of own funds based upon fixed overheads required under CRR Article 97. Although possibly of little more than passing interest to BIPRU firms, the RTS is very relevant to UCITS firms, full-scope [...]
The rules surrounding the need to submit annual report and accounts via GABRIEL using FIN-A upload functionality (see Regulatory Roundup 55) will come into force this coming 31 December. The rules, contained within (new) SUP 16.7A, and FIN-A guidance can be found in Part 2 of Legal Instrument FCA 2014/52. [...]
A reminder to firms that the FCA’s Online Notifications and Applications system (ONA), under which applications for Approved Persons, Variations of Permission etc. are submitted, will be largely replaced by a new online system – ‘Connect’ – from 1 October (although passport applications will remain on ONA). For the avoidance [...]
Firms subject to EMIR should be aware that additional (daily) reporting to a Trade Repository (TR) comes into force on 11 August. As will be known, the obligation to report to a TR under Article 9 of EMIR began on 12 February. The minimum details to be reported to a [...]
As a consequence of falling under CRD IV, IFPRU firms have to submit their COREP returns to the FCA in XBRL format in line with European requirements. The first submission deadline, for the period to 31 March 2014, is June 30 (see Regulatory Roundup 54). Responding to demand from our [...]
A reminder to those firms subject to CRD IV of the 1 July 2014 deadline in respect of the first ‘Country by Country’ disclosure – see Regulatory Roundup 52. This initial disclosure (which does not need to audited) is limited to turnover, number of employees and name, nature of activities [...]
Under SUP 16.12 firms are required to send various data item returns to the FCA, most of which are submitted electronically. Annual report and accounts are an exception in that while they appear on GABRIEL (as NGP003) they have to be submitted manually to the Regulator. The FCA propose automating [...]
Those firms that fall within CRD IV should have received a FCA notification concerning a delay in the final submission date for the first quarterly COREP report by a month to 30 June. Changes have also been made to the submission dates in respect of the reporting of liquidity and [...]
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