By Uma Sheth & Justin Meagher
On 25 January, 2017, the Financial Conduct Authority (FCA) made several changes to their handbook. One such change was to CP 16/17 – Alternative Investment Fund Managers Directive (reporting) Instrument 2017. The change to this instrument closes a significant information gap between the activities and risks incurred by alternative investment fund managers who have a broad presence in the UK.
This change also has sizeable impact on the current reporting requirements of UK alternative investment fund managers (UK managers) as well as non-EEA alternative investment fund managers (non-EEA managers) who file an AIFMD Annex IV report to the FCA. The new rules will come into effect for the reporting period ending June 30, 2017.
For Non-EEA Managers:
Non-EEA managers who currently submit a quarterly AIFMD Annex IV report to the FCA, and market a feeder AIF in the UK, will have to start reporting master AIFs associated with said feeder regardless of where the master AIF is marketed. However, when determining reporting obligations based on AUM thresholds, the AUM of the master AIF that was not marketed in the UK should not be considered. Further, this will likely not impact the current filing frequency for Annex IV reporting of non-EEA managers to the FCA.
The FCA will issue product reference numbers to non-EEA managers who will be required to submit quarterly AIFMD Annex IV reports in respect to their master AIFs. This change does not impact the current reporting requirements of feeder AIFs.
For UK Managers:
UK AIFMs with a semi-annual or annual reporting frequency are not required to complete Article 24(2) of AIF002 transparency report for the non-EEA master AIFs that are not marketed in the EEA. The semi-annual or annual UK AIFMs would still have to complete Article 24(1) and Article 24(4) (when applicable) of AIF002 transparency report on their non-EEA master AIFs not marketed in the EEA.
These changes to the handbook do not impact full-scope UK AIFMs with a quarterly AIFMD Annex IV obligation.
The AIFMD Annex IV solution from SS&C helps to meet your reporting requirements with minimum cost and disruption. To learn how we can help you, download our brochure or contact Richard Clark, Managing Director, Regulatory Reporting at 212-651-5124 or Justin Meagher, Managing Director, Regulatory Solutions at 212-651-5200 firstname.lastname@example.org.