Non-EU Alternative Investment Fund Managers (AIFMs) that
currently complete “Annex IV” regulatory reporting with
the FCA in respect of feeder funds are not required to complete the
Annex IV report in respect of the master fund, on the condition
that the master fund is a non-EEA fund and is not marketed in the
EEA. As a result, non-EEA managers of master-feeder structures
often do not need to satisfy Annex IV reporting in respect of the
The FCA announced on 25 January 2017 a change to this position.
With effect from 29 June 2017, the FCA will require non-EEA AIFMs
also to complete Annex IV in respect of the master fund, regardless
of whether or not the master fund was marketed in the EEA. This
change only applies to an AIFM that currently reports information
to the FCA on a quarterly basis – so it does not apply to an
AIFM that reports either on a half-yearly basis or to most private
equity fund AIFMs that report on a yearly basis.
The position for UK authorized managers will also change. UK
authorized managers that are subject to the quarterly reporting
requirement will need to complete Annex IV for each non-EEA fund
that is not marketed in the EEA. UK managers that are subject to
the reporting requirement for non-EEA master funds (either because
the feeder fund is an EEA fund or is a non-EEA fund that is
marketed in the EEA) will only need to continue to complete Annex
IV for the master fund if they are also subject to the quarterly
The first quarterly Annex IV report for the relevant master fund
will need to be filed by 31 July 2017, for the quarter April to
June 2017. Managers in scope should take steps soon to address the
In taking this step, the FCA has aligned itself with a number of
other EU member state regulators and has acted in accordance with a
power granted by the European Securities and Markets Association
(ESMA) to member state regulators. The FCA consulted on this rule
change in July last year, explaining that the change was designed
to reduce gaps in information received on master funds.
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