The UK's Financial Conduct Authority has now opened GABRIEL, its online reporting portal, to submissions to be made under the Alternative Investment Fund Managers Directive.

The UK's Financial Conduct Authority has now opened GABRIEL, its online reporting portal, to submissions to be made under the Alternative Investment Fund Managers Directive.

As reported often in these web-pages, the regulators' IT people have been dragging their feet for a long time in this area, and not just in the UK. It is to be hoped that the new reporting lines work properly.

The changes introduce five new data items: managers' reports [AIF001]; fund reports [AIF002]; capital adequacy reports for collective portfolio management firms [FIN066]; capital adequacy reports for collective portfolio management investment firms subject to the FCA's prudential 'sourcebook' (rulebook, really) for investment firms, otherwise known as IFPRU [FIN067]; and capital adequacy reports for collective portfolio management firms subject to the prudential sourcebook for banks, building societies and investment firms, otherwise known as BIPRU [FIN068].

The European Securities and Markets Authority (ESMA) published its final guidelines on the reporting obligations for alternative investment fund managers (AIFMs) recently and dictated a reporting deadline of 8th October. The guidelines can be found in every language from Bulgarian to Swedish at: http://www.esma.europa.eu/content/Guidelines-reporting-obligations-under-Articles-33d-and-241-2-and-4-AIFMD-0

Reporting 'dos and don'ts' for Annex IV

The FCA recently came out with some information to do with the reporting of Annex IV transparency information for 'full-scope' UK AIFMs, small authorised UK AIFMs and small registered UK AIFMs. Any firm that is managing and, where relevant, marketing an alternative investment fund (AIF) that is a fund-of-funds, feeder AIF and/or umbrella AIF, should report information in respect of those AIFs according to ESMA's note entitled “Guidelines on reporting obligations under Articles 3(3)(d) and 24(1), (2) and (4) of the AIFMD.”

AIFMs should treat feeder AIFs of the same master fund individually. They should not aggregate all the information on feeder AIFs of the same master(s) in a single report. AIFMs should not aggregate master-feeder structures in a single report (i.e. one report gathering all the information on feeder AIFs and their master AIF(s)). By the same token, when reporting information about an AIF that is a fund-of-funds, AIFMs should not look through to the holdings of the underlying funds in which the AIF invests. When the firm in question reports information about an AIF that takes the form of an umbrella AIF with several compartments or sub-funds, AIF-specific information should be reported at the level of the compartments or sub-funds.

On its information sheet the FCA says it expects GABRIEL to be available for AIFMD transparency reporting on Monday 20 October. AIFMs must report transparency information using the AIF001 and AIF002 reports which they must submit via GABRIEL, the FCA’s online regulatory reporting system.