Currently a non European Economic Area (EEA) Alternative Investment Fund Manager (AIFM) which markets a non-EEA feeder fund in the UK only has to report article 24(2) data (which forms part of the Annex IV reporting information) in respect of the master Alternative Investment Fund (AIF) if that master AIF is itself marketed in the UK. As of 29 June 2017, the Financial Conduct Authority (FCA) will require above threshold non-EEA AIFMs to report article 24(2) data in respect of a non-EEA master fund managed by that AIFM which is not marketed in the UK but whose feeder is so marketed. This change only applies to a non-EEA AIFM if the feeder is subject to quarterly reporting and so will not apply to those who report on a half-yearly or annual basis (yearly reporting being the norm for most private equity funds).
FCA authorised Full scope UK AIFMs which manage a non-EEA AIF where neither the AIF itself nor any feeder is marketed in the UK will also now need to report article 24(2) data if reporting on that AIF is currently required on a quarterly basis.
A Full scope UK AIFM is currently required to report article 24(2) data for a non-EEA master fund it manages but does not market in the UK if the master fund has a feeder fund which is either an EEA AIF or is marketed in the EEA. In future, such an AIFM will only need to report for the master fund if the AIFM itself is subject to quarterly reporting.