Annex IV

BNP Paribas Securities Services has launched an outsourced service for firms filing their Annex IV reports under AIFMD (the Alternative Investment Fund Managers Directive).

Annex IV reporting is time-consuming and obligates hedge funds, private equity and real estate funds to fill in more than 300 data points before submitting this data to their relevant regulator 30 days after the end of the each quarter. Funds of funds are permitted to submit their Annex IV 45 days after the end of each quarter.

Firms outsourcing the compilation and submission of their Annex IV to fund administrators could find themselves under pressure to disclose the document to investors if administration costs are borne by the fund.

A survey conducted by BNY Mellon in conjunction with FTI Consulting on the eve of the implementation of AIFMD (Alternative Investment Fund Managers Directive) found that 13 percent of managers would pass the costs of Annex IV onto the fund, while 29 percent said they would offset some of the costs to the fund.

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.

Managers must continually monitor their Regulatory Assets under Management (RAuM) so as to ensure they do not inadvertently exceed the Annex IV reporting thresholds laid down in AIFMD (the Alternative Investment Fund Managers Directive).

Reporting frequency for Annex IV is determined by RAuM. Hedge funds running between €100 million and €1 billion are expected to file Annex IV on a semi-annual basis, while managers in excess of €1 billion must submit the report quarterly. Those managing less than €100 million must file annually.