The vast majority of registered or authorised AIFMs should be preparing for the first filing of their Annex IV Reports with the Central Bank of Ireland (Central Bank).
AIFMs that were authorised in the early part of 2014 may have already completed their first submission, but the majority of authorised AIFMs and all registered AIFMs will be facing new reporting obligations over the next few weeks.
The objective of Annex IV reporting is to provide Central Banks in the EU with the means of monitoring systemic risk, which is one of the main drivers behind the Alternative Investment Fund Managers Directive (Directive 2011/61/EU).
Who and What?
Registered AIFMs are required to monitor their AUM on an ongoing basis to ensure that they continue to qualify as registered AIFMs, i.e. their AUM must be below the following thresholds:
- €500 million for closed ended unleverged AIFs ; or
- €100 million for open ended AIFs (where leverage is employed by the AIF).
Annex IV Reports for registered AIFMs cover the main instruments in which the AIFM is trading; the markets in which it is a member or where it actively trades; and the diversification of AIF portfolios managed by the AIFM.
Other AIFMs, which are authorised, must complete the full report.
The date for submission of the first Annex IV reports will be between 1 January 2015 and 31 January 2015 for the categories below:
- all registered AIFMs registered before 30 September 2015
- all quarterly reporting authorised AIFMs authorised during 3Q 2015
- all half yearly reporting authorised AIFMs authorised during 2Q and 3Q 2014
- all annual reporting authorised AIFMs authorised before 3Q 2014
AIFMs should complete the AIFM Reporting Template initially published by the ESMA (European Securities and Markets Authority) in November 2013 (updated last week) and submit their Annex IV Reports through the Central Bank’s Online Reporting System Portal (ONR). Authorised AIFMs and AIFMs of investment funds that are authorised by the Central Bank should already be familiar with ONR. Registered AIFMs that have not yet had to use ONR should take the time now to apply for an ONR identification and to familiarise themselves with the ONR system.