Reporting under AIFMD

The Alternative Investment Fund Managers Directive (AIFMD) is aimed at harmonising the way in which fund managers are regulated and operate within the European Union (EU). One new aspect that is arriving for AIFMs is the need to provide regular reporting to their Competent Authorities (CAs) and to make these reports available to investors upon request.

EU AIFMs, for each AIF that they manage, and non-EU AIFMs for each AIF that they market in the EU, must report exposures, leverage and fund centric information including information on turnover, key exposures and portfolio concentrations, a breakdown of their investment strategy, principle markets and instruments employed by the AIFM and the total value of Assets Under Management (AUM) of each fund managed by the AIFM.

This is presenting a fresh challenge to AIFMs as there are still areas that require clarification from the European Securities and Market Authority (ESMA). “Reporting is becoming far more onerous,” said one panellist at the GFD Selling Into Europe Post AIFMD conference in London last week. “Reporting clarity is one of the key things that has to be defined by ESMA. A number of elements have to be reported as and when required by the regulator and this is creating something of a minefield for AIFMs.”

Reports must be made by AIFMs quarterly or half yearly dependent upon the AIF being managed meeting certain thresholds. Half yearly reporting must be made by AIFMs managing portfolios of AIFs whose AUM in total exceed the threshold of €100m or €500m (including assets acquired through use of leverage) but do not exceed €1bn.

For AIFMs managing portfolios of AIFs whose total AUM exceeds €1bn, reporting must be undertaken quarterly.

This reporting obligation is designed to give CAs of AIFMs sufficient information with which to sufficiently supervise the market and contribute to the Europe-wide push towards identification of systemic risk. According to ESMA guidelines, AIFMs should commence reporting to their CAs as of the first day of the first quarter following an AIFM’s authorisation and after they have information to report. 

The ESMA AIFMD reporting guidelines can be found here: http://www.esma.europa.eu/system/files/2013-1339_final_report_on_esma_guidelines_on_aifmd_reporting_for_publication_revised.pdf

Tags: AIFMDReportingESMARegulation