Annex IV Reporting – changes on the horizon for master / feeder structures

If you are marketing a feeder fund in the UK, recent changes set out by the Financial Conduct Authority (FCA) on 25 January 2017 may have implications on your reporting obligations. These changes will affect managers who utilise a master / feeder structure in respect to their Alternative Investment Funds (AIFs), both EU and non-EU. These rules come into effect from 29 June 2017, meaning any qualifying funds need to be reported on by the usual second quarter deadline of 31 July 2017. The key points are as follows.

For UK Alternative Investment Fund Managers (AIFMs):

• UK authorised AIFMs will have to continue to report under articles 24(1) and 24(2) for each non-EEA master AIF that is not marketed in the union if the feeder fund is an EEA AIF or a non-EEA AIF that is marketed in the EEA. However, this only applies if the AIFM is managing both the feeder and the master AIFs and the AIFM is subject to quarterly reporting.
   
• UK authorised AIFMs who manage non-EEA AIFs that are not marketed in the EEA will now have to report information in 24(2) in addition to 24(1), but only if the fund is subject to quarterly reporting.

For non-EEA AIFMs under National Private Placement Regime (NPPR):

• Above-threshold AIFMs marketing a feeder in the UK, are now required to report to the FCA under articles 24(1), (24)2 and 24(4) (if applicable) on the master AIF in addition to the feeder AIF, even if the master AIF is not marketed in the EEA. This only applies if the AIFM manages both the master and feeder AIF and the feeder is subject to a quarterly reporting obligation.

This move by the FCA places the UK’s approach in line with other EU nations such as Belgium, Ireland and Luxembourg who have previously implemented similar changes. 

Langham Hall has been offering a full service Annex IV solution for Private Equity and Real Estate funds since the first reporting cycle in January 2015. We have experience in filing for open and closed-ended vehicles, both private and listed. In this last reporting period alone we filed more than one hundred reports across nine jurisdictions.

If you would like to discuss further our time and cost-effective reporting solution, please do not hesitate to get in touch. We would be happy to assist you and guide you through the process. 

Written by annex IV experts with Langham Hall’s depositary team. For further reading on the amendments made to the Investment Funds (FUND) sourcebook, here is a link to the FCAs publication.

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Joe Hime - Head of UK Depositary
E. joe.hime@langhamhall.com
T. +44 20 3597 7969
M. +44 75 8466 2813