The Financial Conduct Authority (FCA) has increased the reporting requirements to include Master funds even if they are not being actively marketed. This requirement applies to Non-EU Alternative Investment Fund Managers (AIFMs) that market feeder alternative investment funds (AIFs) into the UK under Article 42 of the EU Alternative Investment Fund Managers Directive (AIFMD), a.k.a. “the national private placement regime”. This is applicable to only quarterly Annex IV reports. The effective date of the new requirement is June 29, 2017, which will impact the Q2 2017 (a.k.a. June 30) submissions.
Firms should plan to file the Q2 2017 quarterly Annex IV report by July 31, 2017.
The UK joins the growing list of countries that are requiring master level look-through including Belgium, Germany, Ireland, and Luxembourg.
At present, in the UK under the AlFMD national private placement regime, above threshold non-European Economic Area AIFMs only provide reporting on the actual fund being marketed into the UK, which in a master feeder structure, is typically limited to the feeder fund. However, the rule change requires these firms to now provide full reporting in respect of both feeder AIF(s) being marketed in the UK and their related master AIFs, even if the master AIF is not registered to be marketed.
When Does This Take Effect?
This new rule takes effect on June 29, 2017. Firms should plan to file the quarterly Annex IV report by July 31, 2017 for the previous quarter.
How ACA Can Help
ACA’s Regulatory Reporting Platform supports master-level look-through for Annex IV as now required by the UK’s FCA. The platform is backed by our team of consultants with FCA regulatory experience based in the UK.
For More Information
If you have questions about the UK’s FCA AIFMD master-level reporting requirement, please contact Andrew Welch at +44 (0) 20 7042 0500.
For more information about ACA’s Regulatory Reporting Platform, please contact Chintan Gandhi at +1-212-951-1030.