Fund managers impacted by AIFMD (the Alternative Investment Fund Managers Directive) should begin collecting static data from their counterparties to start populating the Annex IV report so as to avoid a rush when the deadline approaches.

Firms which had received authorisation as AIFMs from their home state regulators by 22 July 2014 are required to file Annex IV reports no later than 31 October 2014. Other affected firms can expect to file Annex IV no later than 31 January 2015, or even April 2015.

The Autorité des Marchés Financiers (AMF), the French regulator, has said it understands some small private equity firms may face challenges providing independent valuation of private assets as mandated under AIFMD (the Alternative Investment Fund Managers Directive), but said the process should be manageable.

The so-called collateral shortfall is unlikely to be as severe as some market participants initially believed, although obtaining high grade eligible collateral to post as initial and variation margin to central counterparty clearing houses (CCPs) could become more challenging.

An alarming number of alternative investment fund managers (AIFMs) had wrongly assumed they could market through AIFMD's (the Alternative Investment Fund Managers Directive's) national private placement regimes and passport to organisations and high-net-worth individuals (HNWIs), even if the latter did not fully adhere to the compliance requirements contained in MiFID (the Markets in Financial Instruments Directive).

Regulators in Europe need to provide private equity and other alternative investment managers with greater clarity about what constitutes reverse solicitation versus active marketing under AIFMD (the Alternative Investment Fund Managers Directive).