UK FCA Annex IV Reporting Amendments for non-EU managers to take effect on June 29, 2017

February 1, 2017

On January 25, 2017 the UK Financial Conduct Authority (FCA) released an amendment to the Financial Services and Markets Act 2000 which confirms the FCA’s plans to increase the scope of Annex IV reporting rules under the EU Alternative Investment Fund Managers Directive (AIFMD). As reported in our detailed alert on July 9, 2016, the amendment expands the current Annex IV reporting requirements applicable to Alternative Investment Fund Managers (AIFMs) domiciled outside of the European Economic Area (“non-EEA AIFMs”) marketing in the UK under Article 42 of AIFMD. The proposed rule change will require above threshold non-EEA AIFMs to provide full reporting in respect of both feeder AIF(s) being marketed in the UK and their related master AIFs, following a similar approach to that taken by Belgium, Ireland and Luxembourg.

Importantly, though, the FCA is not proposing to extend this additional reporting burden to all non-EEA AIFMs, but instead, just those non-EEA AIFMs who are currently required to report on a quarterly basis.

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.

About ACA Regulatory Reporting
ACA Regulatory Reporting (RR) is the single platform solution designed to help today’s investment management community successfully prepare for and respond to evolving regulatory mandates. Architected to be both modular and scalable, RR is an extremely efficient, fast-to-deploy solution for Form PF, AIFMD Annex IV, CPO/PQR, and emerging regulatory reporting obligations. Investment managers can deploy the entire RR platform or select modules that apply to their current needs with the option to add others as new demands arise.

About ACA Compliance (Europe)
ACA Compliance (Europe) is the London-based division of ACA. Our team combines over 100 years’ experience as UK regulatory consultants and includes former FSA and SEC examiners, together with experienced industry practitioners and individuals previously approved as Compliance Officers – a unique offering in Europe. Additionally, our market-leading GIPS® and independent performance verification services, as well as our award-winning cybersecurity solutions are also offered out of London office to better serve European clients.