Small AIFMs - Mind the Transaction Reporting Gap Compliance

or to bookmark this page

Click here to bookmark this page

Click here to remove bookmark

A year on from the Markets in Financial Instruments Directive II (MiFID/MiFIR) and transaction reporting is still an area of confusion for alternative investment fund managers (AIFMs). This is particularly the case for small authorised AIFMs who are unclear on their obligations to undertake transaction reporting when executing orders for individual separate account clients.

In order to unpick the confusion, firms should understand which directive they are authorized under. Full-scope UK AIFMs are not subject to transaction reporting because they are authorized under the Alternative Investment Fund Managers Directive (AIFMD) and are expressly permitted to undertake portfolio management for separate account clients. Small authorized UK AIFMs permitted to undertake individual investment management are authorized under MiFID, and as a result are required to transaction report when undertaking individual portfolio management.
 
On another note, the Financial Conduct Authority (FCA) this week fined a global investment bank £27.6 million for transaction reporting failures relating to 135.8 million transaction reports between November 2007 and May 2017, which is a timely reminder of importance the FCA places on transaction reporting as a critical tool for monitoring market activity.

Small AIFMs - Mind the Transaction Reporting Gap 2019-03-22T04:00:00.0000000 /en/insights/publications/financial-compliance-regulation/small-aifms-mind-the-transaction-reporting-gap /-/media/assets/images/news/featured-images/2019/mind-the-transaction-reporting-gap.jpg publication {4D5F3272-D961-43F9-A68A-1C9C7C28832E} {E175DCD7-26BF-455A-BFA9-4B1CEE3C3B05} {30AC7091-4FBB-401F-B7FB-C6BB4667B5FB} {5D63B63E-5E61-4A73-B8E0-F23D158F3B53} {5C6EBC11-7786-4DA8-BD04-3AA67E5751B7}

Other Areas We Can Help

UK Compliance Services

UK Compliance Services

Comprehensive compliance and regulatory support for FCA authorized firms.

UK Compliance Services
Market Services

Market Services

Assistance with markets, transaction reporting and surveillance.

Market Services

Insights

Cyber

Q3 2021 Threat Landscape: Ransomware in the Supply Chain

Cyber
Restructuring

What’s Ahead for UK Businesses in 2022?

Restructuring
Compliance

Are Your Disclosures and Compliance Programs SEC Compliant?

Compliance