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The AIFMDreporting challenge
A practical guide to meetingAnnex IV requirements
Managing editorsNatasha Shields, Marketing specialist, BNP Paribas Securities Services
ContributorsJohn Vaughan, Head of product, Fund administration and middle office outsourcing, BNP Paribas Securities ServicesGerhard Jovy, Partner, Business development regulatory reporting, acarda SARL
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Table of contents
Foreword
Section 1 – Annex IV reporting in 5 questions
Section 2 – At a glance – Annex IV in figures
Section 3 –Rising to the data challenges of Annex IV
Section 4 – Country profiles
AustriaBelgiumFranceGermanyIrelandItalyLuxembourgMaltaThe NetherlandsSpainUnited Kingdom
Contacts
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Foreword
¡ 7 ¡
Foreword
Foreword
22 July 2014 was an important milestone for managers of alternative investment funds (AIFs) in Europe. This date signalled the end of the Alternative Investment Fund Managers Directive (AIFMD) transitional phase, and the dawn of a new period from which the requirements of the Directive kick‑in for all full scope authorised alternative investment fund managers (AIFMs).
In the run‑up to July, firms had been focusing on meeting the requirement to appoint a depositary and obtaining authorisation for their products. Since gaining authorisation, however, their attention has shifted to complying with the Directive’s reporting obligations.
The AIFMD Annex IV transparency reporting requirements represent a major challenge for fund managers. All authorised and registered AIFMs are required to periodically report to their local regulators on each AIF they manage or market within the European Union. The frequency and the content of the reporting depends on the volume of assets under management, the extent to which leverage is used and whether an AIFM manages only unleveraged AIFs investing in non‑listed companies and issuers in order to acquire control.
Fund managers must disclose details of principal markets and instruments in which the AIFM trades on behalf of the managed fund, along with key instruments that are actively traded and principal exposures and concentrations for each AIF. The AIF reports also cover a number of risk topics including market, counterparty, and liquidity risks.
Compiling the report entails collecting, enriching, classifying and validating data from multiple sources and performing complex calculations. Fund managers must ensure that the reports are delivered on time and in the correct format (which will depend on the system used by the national competent authority in question).
The deadline for the first filing of the AIFMD Annex IV report is a mere 30 days after the end of the first reporting period, once the AIFM has been authorised (although funds of funds have been given 45 days). In order to meet their regulatory responsibilities on time, fund managers must ensure that they have the necessary technical know-how and capabilities in place to meet the challenge of Annex IV.
In light of the complexity of Annex IV and the significant stakes involved, this guide has been produced to support fund managers in meeting its requirements. Drawing on the expertise of BNP Paribas Securities Services and acarda, it provides an overview of the reporting obligations, outlining the main considerations and issues. It also offers an in‑depth look at the data challenges raised by Annex IV. For fund managers who are faced with the prospect of reporting to a number of different national competent authorities, the guide provides compilation of useful information from key European Union member states1.
1 This guide provides the information available at the time of printing (30 September 2014).
John Vaughan
Head of product, Fund administration and middle office outsourcing BNP Paribas Securities Services
Gerhard Jovy
Partner, Business development regulatory reporting acarda SARL
Section 1 – Annex IV reporting in 5 questions
¡ 9 ¡
Section 1
Annex IV reporting in 5 questions
Section 1 – Annex IV reporting in 5 questions
¡ 10 ¡
Why?
The primary reason for the Annex IV reporting requirement is to give regulators the means to monitor systemic risk in the alternative investment fund industry. ESMA has elaborated from a few short paragraphs in the Alternative Investment Fund Managers Directive a detailed and at times complex set of reporting guidelines.
What?
There are two Annex IV reports:
¡ The AIFM report, giving details of the manager and a consolidated view of the assets they manage
¡ The AIF report, which has to be completed for each fund, contains details of the assets held by the fund, the risks to which it is exposed, the types of investor holding shares or interests in the fund and much more
The scope of data to be completed depends on a number of factors including the assets under management (AuM), the degree of leverage, the type of assets held and whether the AIFM is registered or authorised.
Who?
AIFMs need to figure out which category they fit into before they can determine the exact reporting requirements. First, those with less than EUR 100 million under management (EUR 500 million if leveraged) come under the light reporting regime. They have to complete the AIFM report and a limited section of the AIF report for each fund. Non-EU AIFMs who market funds in the EU will have to produce an AIF report for every fund and for each country they market to. Other AIFMs have to complete the full report. Finally there are a number of sections which are conditional on certain types of assets or risk. For example private equity funds must report on cases where they exercise a dominant influence over companies they have shares in, and highly leveraged funds must report the results of their stress tests.
The table below summarises a number of requirements depending on the category of AIFM and its assets.
AIFM typeAssets under management
AIFM report (article 3(3)d, 24.1)
AIF report Fund investments, exposures and concentrations (article 24.1)
AIF reportInstruments traded, turnover, risk profile (article 24.2)
AIF reportBorrowing(Article 24.4)
Registered Below EUR 100 million if AIFs are leveraged or below EUR 500 million if all AIFs are unleveraged
Yes Depending on local regulator
(many have yet to clarify this requirement)
No No
Registered but opted‑in to be authorised
Below EUR 100 million or below EUR 500 million if all AIFs are unleveraged
Yes Yes Yes Yes, if using substantial leverage (Commitment Exposure/NAV > 3)
Authorised AIFMs Above EUR 100 million or above EUR 500 million if all AIFs are unleveraged
Yes Yes Yes Yes, if using substantial leverage
Non‑EU AIFMs marketing AIFs to EU countries
Any Yes Yes Yes Yes, if using substantial leverage
Where?
Broadly speaking all AIFMs are subject to the reporting requirement no matter where they are located as long as they manage one or more AIFs domiciled in an EU country or market AIFs in EU countries.
When?
Some AIFMs have already started filing their Annex IV reports but for the majority the first filing date will be either 31 October 2014 or 31 January 2015. Further details are provided in the country profiles that may be found in the final section of this guide. The frequency of reporting depends on the AIFM and the AIFs. It can be annually, semi-annually or quarterly. Broadly speaking this is determined by the assets under management.
AIFMs may need to report their own data at a different frequency to the AIFs under their management. Similarly, the AIFM may need to report on the AIFs under their management at a different frequency to each other. When factors which influence the report content or frequency change during the reporting period, the picture becomes even more complex, so AIFMs will have to monitor these factors to make sure they submit at the right time.
Frequency of reporting
The European Commission’s Level 2 Regulation sets out the frequency of reporting by AIFMs and whether this needs to be done on a quarterly, semi-annual or annual basis. This is dependent on the AIFM’s assets under management calculated in accordance with Article 2 of the Level 2 Regulation. The table below indicates the frequency of reporting based on the characteristics of the fund manager and the fund.
A helpful decision tree on the frequency of Annex IV reporting for authorised AIFMs, non‑EU AIFMs under Private Placement Regime and registered AIFMs has been produced by the European Securities and Markets Authority (ESMA).
Section 1 – Annex IV reporting in 5 questions
¡ 11 ¡
Annual Half-yearly Quarterly
AIFM reporting AIFM’s AuM:
¡ < EUR 100 million (with leverage)
¡ < EUR 500 million (without leverage)
¡ > EUR 1 billion (if all managed AIFs invest without leverage into non‑quoted companies in order to acquire control of them)
AIFM’s AuM:
¡ > EUR 100 million (with leverage)
¡ > EUR 500 million (no leverage)
¡ < EUR 1 billion
AIFM’s AuM
¡ > EUR 1 billion
AIF reporting + leverage (if required)
AIF invests without leverage into non‑quoted companies or issuers in order to acquire control of them
AIFM’s AuM:
¡ > EUR 100 million
¡ < EUR 500 million + use of leverage
AIFM’s AuM
¡ > EUR 1 billion
Section 2
At a glance – Annex IV in figures
¡ 13 ¡
Section 2 – At a glance – Annex IV in figures
The demands of AIFMD Annex IV
A COMPLEX SET OF REPORTING REQUIREMENTS
DAYS TO COMPLETE
HIGHLY DETAILEDQUESTIONS
41 ?
302DATA FIELDS FOR EACH AIF
9 VARIATIONS OF THEAIFM REPORT
45 VARIATIONS OF THE
AIF REPORT
38DATA FIELDS FOR THE AIFM
Section 3
Rising to the data challenges of Annex IV
¡ 15 ¡
Section 3 – Rising to the data challenges of Annex IV
¡ 16 ¡
Rising to the data challenges of Annex IV
For many managers, producing their first Annex IV reports under AIFMD will be a colossal undertaking. It entails much more than the mere collection and reporting of data. Annex IV involves aggregating information from multiple sources and managing different types of data (including static data, accounting data and risk measurements). Managers are then required to transform and enrich this data before populating the reports.
The Annex IV reporting template consists of 41 highly detailed questions with 340 data fields (38 fields concern the AIFM and 302 fields concern the AIF). It requires fund managers to provide a wide range of information including details of instruments traded, AuM and liquidity, borrowings, exposures, stress test results and leverage. Much of this data had not been previously requested by local regulators.
Some regulators are making use of the flexibility in the ESMA guidelines to make certain optional fields mandatory. A good example of this is in Austria, where all optional fields should be completed when the data is available.
Furthermore, the reports have to be provided a mere 30 days after the end of the reporting period (or 45 days for fund of funds).
5 key data challenges
1) AUM calculation: It sounds simple but for funds that hold derivatives the AUM is not the same as the NAV. A specific calculation is needed to add in the aggregate nominal value of the derivative underlyings
2) Leverage: This is calculated as the risk exposure divided by the NAV – but there are two risk exposure calculation methods (commitment and gross)
3) Classification: ESMA guidelines introduce a completely new classification schema for portfolio assets, which need to be mapped against existing characteristics or classifications held in the reporter’s reference database
4) Submission: Once finalised the report must be rendered into the correct XML version required by the country’s national competent authority, delivered through their submission portal – and the acknowledgement and error messages need to be managed
5) Keeping control: Syntax and logical checks must be performed. Fund managers must make sure that they have a clear audit trail to explain, field by field, where the data originated from, how it was transformed, and if there were amendments, who did what
Given the complexity and volume of data necessary and the approaching deadlines for the report, fund managers who have not already settled the question of Annex IV are well advised to examine its requirements. A sufficient lead-up time should be provisioned, to ensure that the proper processes and systems are in place in advance of the first reporting deadline.
Without the necessary planning and organisation, fund managers risk restless nights and a flurry of activity as the initial deadline looms. Over time, however, it is clear that the process of Annex IV reporting will have to become embedded into the operation of each AIFM. This may require that firms develop the necessary expertise in‑house, supported by adequate systems. Alternatively, fund managers may wish to outsource this role to a competent provider.
Section 3 – Rising to the data challenges of Annex IV
¡ 17 ¡
Engaging a specialist third party to coordinate the process separately from the daily operations of the fund offers a number of advantages. Through outsourcing the burden of regulatory reporting, the AIFM can focus its resources on managing its core activities. In addition, such a partnership permits the fund manager to benefit from the specialist technology of its provider, specifically developed to extract the required information and generate the necessary calculations. Above all, though, by appointing a reputable servicing specialist, fund managers can benefit from the wealth of experience it has acquired through years of managing, interpreting and coordinating diverse regulatory reports.
The AIFM checklist – 10 key actions in preparation for Annex IV
1) Work out your reporting timeline and scope over the coming months, based on funds under management, investment strategies, degree of leverage, date of authorisation/registration, and your national competent authority’s deadlines
2) Determine your production model and set up the means to:
a. Import, record, transform, and control input data
b. Render, validate and submit the reports
3) Gather the necessary static data and define your policy on optional fields
4) Identify the best data sources for the following and establish a transmission process:
a. Holdings
b. Transactions
c. Static data for establishing the ESMA classifications of assets and transactions
d. Investor concentration and breakdown
5) Define on what basis you will determine the investment strategy breakdowns for your funds and calculate/estimate the percentages for each
6) Review the risk data to be reported and determine which sources you will use
7) Determine the best source of data on historical performance and subscription and redemption activity (for the historical risk section)
8) Make sure you have the data which is conditional on certain types of fund (for example leverage and sources of borrowing, dominant influence and controlled structures)
9) Test the data management process, especially classification mapping and assets under management calculation
10) Test the end-to-end process with real fund data before the end of the first reporting period, including submission
Section 4
Country profiles
AIFMD
Transposed
Local industry body
Austrian Association of Investment Fund Management Companies (Vereinigung Österreichischer Investmentgesellschaften – VÖIG).
www.voeig.at/
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The Austrian authorities have gone further than the minimum ESMA requirements. AIFMs are expected to report all mandatory fields and also all optional fields when data is available.
Section 4 – Country profiles
¡ 19 ¡
Section 4 – Country profiles
¡ 19 ¡
Austria
The date of the first report and first reporting period
31 October 2014 is the deadline for submission of the reports for the third quarter of 2014. The next reporting deadline is 31 January 2015.
Links to main reference documents of the national competent authority
Guidelines in for investment managers (in German):
www.fma.gv.at/de/unternehmen/investmentfonds‑kag/informationen‑fuer‑verwalter‑alternativer‑investmentfonds.html
Information on the technical submission channel for the country and the report format options
The Austrian Authorities expect the report to be submitted in version 1.2 of the ESMA xml schema. They do not allow third parties to submit on behalf of managers.
Further information is available at:
www.fma.gv.at/de/unternehmen/banken/incoming‑plattform.html
National Competent Authority
Finanzmarktaufsicht (FMA)
www.fma.gv.at/en/homepage.html
AIFMD
Transposed
AIFMD
Transposed
Section 4 – Country profiles
¡ 20 ¡
Belgium
The date of the first report and first reporting period
The first reports are due on 31 January 2015, and thereafter the submission timeline is aligned with the ESMA guidelines.
Links to main reference documents of the national competent authority
http://www.fsma.be/en/Supervision/finprod/icb.aspx
Information on the technical submission channel for the country and the report format options
The electronic reporting platform in Belgium is called FiMiS. It is possible to submit the required data by manual input or by uploading the appropriate XML files (in which case ESMA version 1.2 is expected).
Test facilities will be made available.
Local industry body
Belgian Asset Managers Association (BEAMA)
www.beama.be
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The FSMA has decided to collect the supplementary data mentioned in the ESMA “Opinion”
Additional information
¡ If there is any free text in the report it has to be in English.
National Competent Authority
Financial Services and Markets Authority (FSMA – Autorité des services et marchés financiers/Authoriteit voor Financiële Diensten en Markten)
www.fsma.be/en.aspx
AIFMD
Transposed
AIFMD
Transposed
Section 4 – Country profiles
¡ 21 ¡
France
The date of the first report and first reporting period
Registered AIFMs
For AIFMs registered in Q3 2013, the first annual report was due on 31 January 2014. For AIMFs registered after that date the first annual report is due on 31 January 2015.
Authorised AIFMs
AIFMs authorised before the end of Q2 2014 have to report for the first time on 31 October 2015. If they are authorised after that date their first report is due on 31 January 2015.
Links to main reference documents of the national competent authority
Guide for asset managers:
www.amf‑france.org/Publications/Guides/Professionnels.html?docId=workspace%3A%2F%2FSpacesStore%2F87bc82b4‑bc90‑4dfa‑84dd‑a3d0259ae479
Information on the technical submission channel for the country and the report format options
The submission system used in France for Annex IV reporting is GECO
3 methods of submission are available:
¡ Use of the standard GECO form, with single field inputs and validation during input
¡ Upload of XML file with consistency checks during upload
¡ Transmission of XML file with protocol for consistency checks and acknowledgement of receipt
Local industry body
L’Association Française de la Gestion financière
www.afg.asso.fr
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The requirements are in line with the ESMA guidelines. The content under 24(5) is not required.
National Competent Authority
Autorité des Marchés Financiers (AMF)
www.amf-france.org/
AIFMD
Transposed
AIFMD
Transposed
Section 4 – Country profiles
¡ 22 ¡
Germany
The date of the first report and first reporting period
For Q2 (if requested by BaFin), Q3 & Q4 2014, AIFMs have from 16 to 31 March 2015 to submit the reports. The reporting deadlines for subsequent deadlines are as follows:
¡ Q1 2015: 30 April 2015
¡ Q2, H1 2015: 31 July 2015
¡ Q3 2015: 31 October 2015
¡ Q4, H2, full year 2015: 31 January 2016
Links to main reference documents of the national competent authority
Guidance Notice on the reporting obligations of AIF‑Management Companies pursuant to section 35 of the German Investment Code (Kapitalanlagegesetzbuch – KAGB)
www.bafin.de/SharedDocs/Veroeffentlichungen/EN/Merkblatt/mb_140815_meldepflicht_aif‑vwges‑35kagb_en_wa.html
Information on the technical submission channel for the country and the report format options
In Germany the MVP‑Portal system is expected to be ready for testing in February 2015. This system will accept ESMA XML version 1.2.
https://portal.mvp.bafin.de/MvpPortalWeb/app/login.html
Local industry body
The main industry body is the German Investment Funds Association (BVI)
www.bvi.de/regulierung/positionen/aifm‑richtlinie‑aifmd
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The BaFin does not require any additional optional fields. Field 24(5) is not required.
Additional information
¡ Retrospective reporting is currently being planned. The reports should be delivered from 16 March to 31 March 2015
¡ Retrospective reporting starting from the quarter after reference date (for AIF Kapitalverwaltungsgesellschaften, which make a use of the KAGB transition regulations, it is the date when the BaFin receives the AIF application, for all others the date of authorisation/registration)
National Competent Authority
BaFin (Bundesanstalt fu..r Finanzdienstleistungsaufsicht)
www.bafin.de/EN/Homepage/homepage_node.html
AIFMD
Transposed
AIFMD
Transposed
Section 4 – Country profiles
¡ 23 ¡
Ireland
The date of the first report and first reporting period
The first reports relating to the first half of 2014 were due on 11 September 2014. Reports for the third quarter are due on 31 October 2014.
Links to main reference documents of the national competent authority
www.centralbank.ie/regulation/marketsupdate/Pages/AIFMD.aspx
www.centralbank.ie/regulation/industry‑sectors/funds/aifmd/Pages/default.aspx
Information on the technical submission channel for the country and the report format options
The reports have to be uploaded to the ONR portal in XML format. During a transitional period the Authority is accepting Excel format.
The website is https://onlinereporting.cbfsai.ie/Login?ReturnUrl=%2f
Local industry body
The Irish Funds Industry Association (IFIA), is the representative body for the international investment fund community in Ireland.
www.irishfunds.ie
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The Bank of Ireland has kept to the ESMA guidelines.
National Competent Authority
Central Bank of Ireland
www.centralbank.ie
AIFMD
Transposed
AIFMD
Transposed
Section 4 – Country profiles
¡ 24 ¡
Italy
National Competent Authority
Banca d’Italia
https://www.bancaditalia.it
Consob
www.consob.it
AIFMD
Transposed
The date of the first report and first reporting period
In Italy AIFMD is not yet live. The 22 July 2014 deadline has been officially postponed to 31 December 2014. It seems that the AIFMs will have to report for the first time during the second quarter of 2015. However, this has not yet been confirmed by the regulator.
Links to main reference documents of the national competent authority
www.bancaditalia.it/vigilanza
www.consob.it/main/documenti/Regolamentazione/lavori_preparatori/consultazione_consob_bancaditalia_20140626.htm?symblink=/main/regolamentazione/consultazioni/ln_consultazioni.html
As at September 2014, specific documentation on AIFMD reporting had not been made available by the regulator.
Information on the technical submission channel for the country and the report format options
Details of the submission files in XML format are available. It is also possible that the AIFMs will be allowed to submit their reports in Excel format but details are not yet available.
Local industry body
Assogestioni
www.assogestioni.it/index.cfm/1,147,5794,49,html/aifmd‑la‑proposta‑di‑direttiva‑in‑materia‑di‑gestori‑di‑fondi‑alternativi‑sviluppi‑recenti
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
As the details of Annex IV reporting have not yet been confirmed by the regulator, this was not available at the time of printing (30 September 2014).
AIFMD
Transposed
Local industry body
The Association of the Luxembourg Fund Industry (ALFI) is the official representative body for the Luxembourg investment fund industry.
www.alfi.lu
ALFI has released a Q&A on AIFMD reporting and guidance on AIFMD reporting to investors and annual reports.
www.alfi.lu/node/2772
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The CSSF has stated that it will follow the ESMA Opinion in requiring the additional data (if relevant) mentioned under article 24(5) of the Directive. Further details are provided in the ALFI Q&A (link above).
Additional information
¡ Text files must be in English.
Section 4 – Country profiles
¡ 25 ¡
Luxembourg
National Competent Authority
Commission de Surveillance du Secteur Financier (CSSF)
www.cssf.lu
AIFMD
Transposed
The date of the first report and first reporting period
Authorised AIFMs
AIFMs authorised before the end of Q2 2014 with a quarterly reporting obligation have to report for the first time on 31 October 2015. If they are authorised after that date or report on a semi‑annual or annual basis their first report is due on 31 January 2015.
Links to main reference documents of the national competent authority
www.cssf.lu/en/supervision/ivm/aifm/regulation/european‑documentation/
Information on the technical submission channel for the country and the report format options
Reports (in XML version 1.2) are to be uploaded to the e‑File reporting portal.
www.cssf.lu/en/supervision/ivm/aifm/legal‑reporting/file‑transport‑and‑data‑protection/
AIFMD
Transposed
Section 4 – Country profiles
¡ 26 ¡
Malta
National Competent Authority
Malta Financial Services Authority (MFSA)
www.mfsa.com.mt/pages/viewcontent.aspx?id=506
AIFMD
Transposed
The date of the first report and first reporting period
Reports relating to the periods Q1, Q2, and H1 2014 must be submitted by 1 October 2014. For reports relating to Q3 2014, the deadline is 1 December 2014. For reports relating to Q4, H2, and full year 2014, the submission deadline is 31 January 2015.
Links to main reference documents of the national competent authority
www.mfsa.com.mt/pages/announcements.aspx?id=23
Information on the technical submission channel for the country and the report format options
Submission is possible in Excel format or XML (version1.2). Submission by email is allowed pending set up of an on‑line reporting portal.
Local industry body
Malta Funds Industry Association
www.mfia.org.mt/
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
Field 24(5) is required for quarterly and half‑yearly reporters.
AIFMD
Transposed
Section 4 – Country profiles
¡ 27 ¡
The Netherlands
National Competent Authority
De Nederlandse Bank (DNB)
www.dnb.nl/
AIFMD
Transposed
The date of the first report and first reporting period
It is likely to be due early 2015 for the second half of 2014 but this is to be confirmed.
Links to main reference documents of the national competent authority
www.dnb.nl/en/statistics/eline‑dnb/aifmd/
http://www.dnb.nl/en/binaries/301794_Q&A_reporting_requirements_AIFMD_(30‑12‑2013).pdf
Information on the technical submission channel for the country and the report format options
The report must be submitted in XML format by means of on‑line submission to the dedicated web portal of the DNB: e‑Line DNB.
www.dnb.nl/en/statistics/eline‑dnb/login/index.jsp
Local industry body
Dutch Fund and Asset Mnagement Asociation (DUFAS)
www.dufas.nl/index.cfm/go/English/
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The Netherlands follows the ESMA guidelines. There are no additional mandatory fields.
AIFMD
Pending Transposit
ion
Section 4 – Country profiles
¡ 28 ¡
Spain
National Competent Authority
Comisión Nacional del Mercado de Valores (CNMV)
https://www.cnmv.es
AIFMD
Pending Transpositi
on
The current status of implementation of the Directive and the expected timing of the first report and first reporting period
The AIFMD has not yet been transposed into Spanish law. It is therefore unclear when the Directive will come into effect and how the local regulator will adopt the rules. As at September 2014, no dates have been published. However we expect the general guidelines of ESMA to be followed. With this in mind, the first mandatory reporting period would be the calendar quarter following authorisation, at the earliest.
Links to main reference documents of the national competent authority
https://www.cnmv.es
Information on the technical submission channel for the country and the report format options
As at September 2014, this information had not been made available.
Local industry body
INVERCO, the Spanish Association of Investment and Pension Funds
www.inverco.es
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
As at September 2014, this information had not been made available.
Additional information
¡ CNMV has addressed some clarification questions regarding reporting to ESMA. As at September 2014, the responses had not been published.
AIFMD
Transposed
Section 4 – Country profiles
¡ 29 ¡
United Kingdom
National Competent Authority
Financial Conduct Authority
www.fca.org.uk/firms/markets/international-markets/aifmd/uk-aifms
AIFMD
Transposed
The date of the first report and first reporting period
The date for the first reports is 31 October 2014. A platform called “Gabriel” accepts data feeds in XML and Excel templates. Further information may be found via the following link:
www.fca.org.uk/firms/markets/international‑markets/aifmd/reporting
Links to main reference documents of the national competent authority
www.fca.org.uk/firms/markets/international‑markets/aifmd/reporting?category=frequently‑asked‑questions
Information on the technical submission channel for the country and the report format options
In the UK submission is allowed by Excel or XML file into the reporting system Gabriel.
www.fca.org.uk/firms/systems‑reporting/gabriel/system‑information/data‑reference‑guides/aifmd
Local industry body
The Investment Management Association
www.investmentfunds.org.uk/ukims/regulation/
How are mandatory/optional fields and other points included in the ESMA “Opinion” dealt with?
The FCA has kept to the ESMA guidelines; there are no additional mandatory fields.
Contacts
About BNP Paribas Securities Services
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acarda offers a comprehensive regulatory reporting and data management platform covering all European legislations. The platform comprises an all‑in‑one AIFMD reporting and risk monitoring service. Additional services available on the platform include Key Information Documents and Solvency II “look‑through‑data” for European investors and administrators.
For more information or to contact us, please visit www.acarda.de/public/en
¡ 31 ¡
Contacts
The information contained within this document (‘information’) is believed to be reliable but BNP Paribas Securities Services does not warrant its completeness or accuracy. Opinions and estimates contained herein constitute BNP Paribas Securities Services’ judgment and are subject to change without notice. BNP Paribas Securities Services and its subsidiaries shall not be liable for any errors, omissions or opinions contained within this document. This material is not intended as an offer or solicitation for the purchase or sale of any financial instrument. For the avoidance of doubt, any information contained within this document will not form an agreement between parties. Additional information is available on request.
BNP Paribas Securities Services is incorporated in France as a Partnership Limited by Shares and is authorised and supervised by the ACPR (Autorité de Contrôle Prudentiel et de Résolution) and the AMF (Autorité des Marchés Financiers).
BNP Paribas Securities Services, London branch is authorised by the ACPR, the AMF and the Prudential Regulation Authority and is subject to limited regulation by the Financial Conduct Authority and Prudential Regulation Authority. Details about the extent of our authorisation and regulation by the Prudential Regulation Authority and regulation by the Financial Conduct Authority are available from us on request. BNP Paribas Securities Services, London branch is a member of the London Stock Exchange. BNP Paribas Trust Corporation UK Limited (a wholly owned subsidiary of BNP Paribas Securities Services), incorporated in the UK is authorised and regulated by the Financial Conduct Authority.
In the U.S., BNP Paribas Securities Services is a business line of BNP Paribas which is incorporated in France with limited liability. Services provided under this business line, including the services described in this document, if offered in the U.S., are offered through BNP Paribas, New York Branch (which is duly authorized and licensed by the State of New York Department of Financial Services); if a securities product, through BNP Paribas Securities Corp. or BNP Paribas Prime Brokerage, Inc., each of which is a broker‑dealer registered with the Securities and Exchange Commission and a member of SIPC and the Financial Industry Regulatory Authority; or if a futures product through BNP Paribas Securities Corp., a Futures Commission Merchant registered with the Commodities Futures Trading Commission and a member of the National Futures Association.
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