Insights

ESMA’s revised “Questions and Answers on Application of the AIFMD”

On 9 January 2015, ESMA issued an updated version of its “Questions and Answers on Application of the AIFMD”. They include new Questions and Answers in ‘Section III: Reporting to national competent authorities under Articles 3, 24 and 42’ of AIFMD. The questions relate to subscriptions and redemptions over the reporting period, the change in NAV and investment returns per month, and finally when AIFMs should report aggregated information.

Question 50

[last update 9 January 2015]: How should AIFMs report information on subscriptions and redemptions over the reporting period (questions 255 to 278 of the consolidated reporting template)? 

  • Answer 50: AIFMs should report the value of subscription and redemption orders and not the number of subscription and redemption orders. Information should be reported for the month of the cash-flows and not for the month of the subscription and redemption orders unless it is the same month.
    For example, an AIFM is subject to quarterly reporting obligations and investors can subscribe/redeem 4 times per year on the NAVs of 31/03, 30/06, 30/09 and 31/12 of each year. The AIFM receives for January 100 redemption orders, for February 200 redemption orders and for March 50 redemption orders (350 redemption orders in total over the reporting period Q1). Redemption orders are executed in April on the NAV calculated on 31 March. The NAV is €100 per share. Therefore, the AIFM will report redemption orders for a total value of €35,000 (350*100) in April (reporting for Q2). 

 

AIFMD

Question 51

 [last update 9 January 2015]: How should AIFMs report information on the change in NAV per month (questions 243 to 254 of the consolidated reporting template)?

Answer 51: The change in NAV captures both the change due to subscriptions and redemptions and the change due to investment performance. It is the net effect on the fund’s NAV over the given reporting period after all inflows, outflows and performance are taken into account. AIFMs should report information on the change in NAV for each month of the reporting period. If no official NAV is available for the calculation, AIFMs should use estimates of the NAV. In some cases (e.g. for AIFs investing in illiquid assets), the best estimate may be the previous NAV.  

AIFMD

Question 52

[last update 9 January 2015]: How should AIFMs report information on the percentage of gross and net investment returns per month (questions 219 to 242 of the consolidated reporting template)?

Answer 52: AIFMs should report the information for each month of the reporting period. If no official NAV is available for the calculation, AIFMs should use estimates of the NAV.
In some cases (e.g. for AIFs investing in illiquid assets), the best estimate may be the previous NAV.

AIFMD

Question 53

[last update 9 January 2015]: An AIFM manages both funds and funds of funds. When should the AIFM report aggregated information at the level of the AIFM (AIFM file of the consolidated reporting template)?

Answer 53: In that case, the AIFM should report aggregated information at the level of the AIFM and on funds of funds no later than 45 days after the end of the reporting period. Information on AIFs that do not take the form of fund of funds should be reported 1 month after the end of the reporting period as required by Article 110 of the implementing Regulation.

AIFMD
Did you find this useful?