Reporting - Financial Conduct Authority

Reporting

On 1 October 2013 ESMA published its guidelines on the reporting obligations for Alternative Investment Fund Managers (AIFMs), together with an Opinion setting out supplementary information that should be reported for systemic risk monitoring. These guidelines were subject to minor updates by ESMA on 15 November and have been published on ESMA’s website.

We are consulting on integrating this material into our Handbook in CP14/4. The consultation closes on 6 may 2014. ESMA has also provided additional technical guidance on how to report and a consolidated reporting template.

We are aware that firms that are already authorised will, in certain circumstances, be required to provide regulatory reports to us in Q1 2014. As such, we will be in a position to receive reports from 1 January 2014. We request firms to report using the XML v1.1 reporting template published by ESMA with the final guidelines.

Submitting your data

Please submit your completed returns, using the XML v1.1 reporting template, to: firm.queries@fca.org.uk

The subject line of the email should contain your FRN (or firm name for new applications) followed by 'AIFMD Reporting'. We will send an acknowledgement email to confirm receipt.

Firms are only expected to submit one XML return, no further attachments should be included in the email.

Frequently asked questions

Q1: When will the first report be due and what will the reporting period be?

Answer:

Reporting is based on when the firm becomes an authorised AIFM or from the date of notification when making a notification under the National Private Placement Regime.

Reporting will be due for the first full quarter following authorisation. For example, an AIFM authorised in Q4 2013, and subject to quarterly reporting, will be required to report at the end of Q1 2014. Please refer to ESMA’s final guidelines for further information.

Q2: How often is my firm required to report?

Answer:

Reporting frequency is set out in Article 110 of the Level 2 Regulation. Based on the frequency rules outlined in Article 110 we will initially schedule your returns in GABRIEL upon authorisation. It will then be the firm’s responsibility to ensure that the ongoing reporting frequencies are met by indicating and changes from those in GABRIEL by using the appropriate reporting change notification sections in the XML file/s. 

Q3: How does my firm report a nil return?

Answer:

The ‘AIFM no reporting flag’ field should be completed as “true” when no information to report for AIFs in the reporting period.

Q4: Should the report be in Sterling, Euros or the base currency of the fund?

Answer:

Returns should be submitted in the base currency of the fund.

Q5: Is it mandatory for submissions to be provided in XML format?

Answer:

No. Until October 2014 we will accept data in xml, xls or xlsx formats. After October 2014, we will only accept reporting via XML and online via GABRIEL.

Q6: Will the FCA be setting up a test system for the delivery of AIFMD reporting?

Answer:

Yes, firms will be able to use our GABRIEL Pre-production environment to test their XML submissions.

Q7: Is there technical guidance available to help complete the fields in the return?

Answer:

Yes, we encourage firms to refer to ESMA’s reporting guidelines, technical guidance, opinion and Q&A’s on AIFMD.

Q8: Where an AIFM only markets feeder funds into the EU (the master funds are not marketed into the EU) does the AIFM only need to complete Annex IV for the feeder funds marketed into the EU or are they required to provide information on the corresponding Master fund as well?

Answer:

An AIFM will need to report at the feeder fund level and only identify the master fund for each feeder reported on.

Q9: What should be reported if an AIF is liquidated during the reporting period?

Answer:

The AIFM should provide the report for the last reporting period of the AIF immediately after it has been liquidated.

Q10: Will there be automated validation checks which will be executed on delivery of the return?

Answer:

Yes, once the firm has uploaded their XML file into GABRIEL it will be subjected to various schema and business validations. Any issues with the file or the data will be made available to the firm in order to make the relevant corrections. These business validations will be published as soon as we are able to.

No validation checks will be performed on returns submitted prior to October 2014.

Q11: What are the reporting requirements for non-EEA AIFMs?

Answer:

Non-EEA AIFMs should report all AIFs marketed in the UK to the FCA.

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