The FCA issued information on their website on the AIFMD Transparency Reporting (Annex IV) requirements yesterday. There are two documents, one for Full Scope AIFMs and Small Authorized AIFMs and the other for Non-EEA AIFMs. These will be emailed to all AIFMs authorized by the FCA and those Non-EEA AIFMs that have made an Article 42 notification, and are currently available on the FCA website.
The documents focus largely on the process of submitting the required reports to the FCA and also what correspondence you will receive from the FCA to enable you to be in a position to file the required reports.
Now that the 22 July 2014 deadline has passed, AIFMs (both UK/EEA and Non-EEA) should be making sure that AIFMD Transparency Reporting is at the top of their agenda. Firms should be putting in place processes which will enable them to be ready to submit their first AIFMD Transparency Report.
With respect to FCA transparency reporting, AIFMs should ensure they:
establish the period which their first transparency report will cover;
identify which AIFs need to be included in the reports and which sections of the Transparency Report they need to submit;
determine what information they will need to collate or obtain to enable them to complete the required reports
understand the guidance on reporting produced by ESMA and any relevant competent authorities;
understand the process for reporting to the FCA; and
ensure they have the correct systems in place to enable them to complete and submit these reports in the required format.
Non-EEA AIFMs which have filed Article 42 notifications in EEA States other than the UK will need to appraise themselves of the transparency reporting provisions established by the respective National Competent Authorities.
All AIFMs authorized between 1 July 2014 and 30 September 2014 and all Non-EEA AIFMs that filed an Article 42 notification to the FCA during this period will need to make their first report for the period from 1 October 2014 to 31 December 2014, and this report will need to be submitted within one month. Firms which were authorized or made a notification prior to 1 July 2014 may already be reporting or due to report in advance of this date.