On 30 November 2015, the Central Bank of Ireland (the "CBI") updated its Reporting Guidance for Alternative Investment Fund Managers ("AIFM") (the "Reporting Guidance"), which prescribes new reporting requirements applicable to non-EU master AIFs not marketed in the EU that have either EU or non-EU feeder alternative investment funds ("AIFs") marketed in the EU under Article 42 of AIFMD. Under the Reporting Guidance, the CBI now requires all AIFMs to report information on non-EU master AIFs from the 1 January 2016 reporting period. It should be noted, however, that this information is not required to be reported where the non-EU master AIF and feeder AIF do not have the same AIFM.
This new requirement follows recommendations made by ESMA in its opinion on the collection of information for the effective monitoring of systemic risk under Article 24(5) of AIFMD of 1 October 2013 and is in compliance with the updated Q&A under Section III of the ESMA Q&A on the application of AIFMD of 21 July 2015.
Next Steps
Managers or their reporting agents are advised to contact the CBI by email at aifmdreporting@centralbank.ie to request an AIF National Code (i.e. 'C' number) for the non-EU master AIF and to include the following information as part of that email:
1. Name of the AIFM;
2. Name of the non-EU master AIF; and
3. Appointment date of the AIFM to the non-EU master AIF.
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.
