The Central Bank has clarified the dates by which alternative investment fund managers are required to make their first reports under Regulations 4 (3) (d) and Regulation 25 of the Alternative Investment Fund Manager Regulations.
The Alternative Investment Fund Managers Directive (“AIFMD”) introduced a requirement for an alternative investment fund manager ("AIFM") to supply its competent authority with certain information on an ongoing basis, including, for example; the main instruments in which it’s trading, the markets where it actively trades or is a member, and the principal exposures and concentrations in the portfolios of the alternative investment funds it manages. The reporting obligations are designed to provide competent authorities with information that enables them to supervise the AIFMs under their responsibility, and to contribute to the monitoring of systemic risk on a European-wide basis.
The extent of the AIFMD reporting obligations depends on the status of the AIFM; authorised AIFMs are subject to detailed reporting requirements, while registered AIFMs have to comply with a lighter reporting regime. The frequency with which an AIFM is required to report to the Central Bank will depend on the amount of assets under management in the portfolios of the AIFs it manages and the investment policy of those AIFs. Reporting may thus be on either a quarterly, half-yearly or annual basis.
AIFMs will be glad to know that the Central Bank has set an extended deadline for the first reporting submission; AIFMs which are required to report on a quarterly or semi-annual basis will have up to ten weeks to submit their first report, with information on the reporting period ending 30th June 2014 due to be submitted no later than 11th September 2014. As the AIFMD reporting obligations are a new departure for the alternative investment fund industry, this extended submission deadline should be helpful in allowing AIFMs get to grips with compiling their first report. All subsequent reports must be submitted within one month of the relevant period end.
AIFMs subject to an annual reporting requirement have not been afforded an extended deadline for their first reports. Thus, information for the period ending 31st December 2014 must be submitted by 31st January 2015.
The Central Bank has issued the following table which details the first submission dates:
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The Central Bank has stated that the AIFMD reporting submission dates indicated are subject to change, but they will endeavour to keep to these dates. The Central Bank will contact AIFMs prior to the first submission date, and a test system will be in place in advance of the first submission deadline.