UK ups AIFMD reporting requirements

Non-EEA alternative investment fund managers will be required to file Annex IV reports for both feeder and master funds from June.

Non-European fund managers that market alternative investment feeder funds in the UK under the national private placement regime will be subject to increased reporting requirements from June.

Affected managers – for example US firms that market feeder funds in the UK – will be required to report details of the master AIF’s manager and the AIFs they are managing and/or marketing to the UK regulator on a quarterly basis. This will be alongside the same details they already report every three months for the feeder fund.

The new rules will apply to AIFMs that currently submit quarterly Annex IV reports for their feeder AIF and to AIFMs that manage both the master and the feeder fund.

The first quarterly Annex IV report for master AIFs must be submitted to the Financial Conduct Authority by July 31.

“Although the FCA has stated that it will be contacting those non-EEA AIFMs affected by the changes, AIFMs affected by the new requirements should be taking appropriate steps to ensure that the required information is reported within the applicable time frames,” John Verwey, partner at Proskauer, said in a client update.

The change brings the UK in line with existing guidance from the European regulator – the European Securities and Markets Authority – and the approach of some other European regulators that already require non-EU AIFMs to file Annex IV reports for the relevant master AIFs.