Latest AIFMD reporting guidelines are out

ESMA says GPs must treat feeder funds individually for the purposes of AIFMD.

The European Securities and Markets Authority (ESMA), the pan-EU regulator responsible for enforcing the Alternative Investment Fund Managers Directive, published an updated set of guidelines for the directive’s reporting requirements.

In a departure from prior understanding, ESMA said fund managers with feeder funds must provide reports on those funds individually, and not aggregate the information with the master fund in a single report. Each feeder fund must report its total amount of investments and the name of its master fund, among other requirements.

However, each individual feeder fund does not need to report where its master fund invests, instead a separate master fund filing will cover those details, ESMA said in its guidance. Much in the same way to reduce redundant information filings, fund of funds do not have to report on the underlying holdings of the funds in which they have invested.

The guidelines also state that fund managers should always indicate the value of their investments in Euros. For any currency conversions, GPs should use rates provided by the European Central Bank (ECB), or if there is no ECB conversion rate, disclose what conversion rate is being used.

GPs authorized under the AIFMD, but have not yet made any investments from their AIFMD-authorized fund, must still meet their reporting obligations, ESMA clarified. The regulator said managers could report that certain information on investment activity is not yet available by using specified fields.