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The Cyprus Securities and Exchange Commission has issued a circular (C295 dated 30 January 2019) to managers of Alternative Investment Funds (AIFs) it authorises and to Registered Alternative Investment Fund Managers clarifying their reporting obligations under articles 4(3)(d) and 31 of the AIFM Law.
The Cyprus Securities and Exchange Commission has issued a
circular (C295 dated 30 January 2019) to managers of Alternative
Investment Funds (AIFs) it authorises and to Registered Alternative
Investment Fund Managers clarifying their reporting obligations
under articles 4(3)(d) and 31 of the AIFM Law, particularly
as regards to the inception date of the fund, which is linked
with its first reporting date.
Specifically, although the inception date is defined as
"the date the AIF started business", for purposes of
reporting, the AIF Reporting Template should be completed and
submitted even in cases where the AIF has not started any business.
In this case, the license or establishment date (in the event where
the AIF is established after its license date) should be indicated
as the inception date.
The reporting requirements apply to all Cyprus-based AIFMs and
self-managed AIFs whose total assets under management exceed the
thresholds of articles 4(2)(a) or 4(2)(b) of the Alternative
Investment Fund Managers Law ('AIFM Law') as the case may
be, or which have opted in to the reporting regime under article
4(6).
The circular is available on the CySEC website via this link.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.