Navigating Regulatory Reporting for Alternative Investments: AIFMD Compliance Insights
The European Union (EU) has commenced regulations for Alternative Investments managed or marketed in the European Economic Area (or EEA). The reporting obligation shall depend upon the Asset under Management (or AuM) of the fund marketed or managed in the EU and leverage level of the fund.
This regulation requires that sufficient data is provided to the National Competent Authorities (or NCAs) to study systematic risk in the Alternative Investment Funds which may affect the EU fund industry. The following data parameters are used:
- AuM and liquidity
- Instruments traded
- Concentration of assets and market
- Borrowings and exposures
- Stress test and risk matrix
- Investor ownership and classification
- Leverage
This regulation covers mainly Hedge funds, Private Equity funds and other commonly pooled funds in the EU and Non-EU fund houses, which are not;
- Undertaking for Collective Investment in Transferable Securities (UCITS)
- Closed Ended Funds which shall cease to continue after July 22, 2016 and
- had not made any new investments after July 22, 2014; or
- had not raised subscription after July 22, 2011
- Proprietary or Group companies investing for their own benefits
- Special Purpose Vehicles
- Specific Real Estate Funds with a minimum lock-in period of 5 years
Alternative Investment Fund Managers (AIFMs) are obligated to submit a report called Annex IV to their respective NCAs in designated time periods depending upon their AuM. Following are the deadlines and filing frequencies.
| Filing Frequency | AuM | Deadlines |
| Quarterly | Above Euro 1 Billion at AIFM level or Euro 500 Million at AIF level | 30th April, 31st July, 31st October and 31st January |
| Half yearly | Above Euro 100 Million and below Euro 1 Billion at AIFM level | 31st July and 31st January |
| Annually | Below Euro 100 Million or below (without leverage) at AIFM level | 31st January |
The Annex IV template is categorized into various sub-sections which are applicable based on structure of the fund.
| Templates to be filed | Applicability |
| AIF 24 (1) & AIF 24(2) | Funds which are marketed and managed in EU |
| AIF 24 (1) | Funds which are not marketed, but only managed in EU |
| AIF 24 (4) | Funds which are leveraged, more than 3 times of their NAV |
| AIF 3 (3) (d) | This is same as 24 (1). This has to be reported to NCAs when requested |
Each AIFM has to understand the following for complying effectively with the regulation to answer the 340 questions in the template.
- Funds structure
- Information required by regulators
- Data required to answer the respective questions in templates
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