AIFMD reporting survey
What lies ahead, what went before?
The principle objective of the survey was to assess the reporting experience from the first cycle of the Alternative Investment Fund Managers Directive (AIFMD) reporting. As previously mentioned, much time, effort, and debate had gone into the exercise, perhaps more than expended on any endeavor in recent years, notwithstanding the massive mobilization of resources of all types that went into the production of the key investor information document (KIID) and other such exercises.
In addtion, we set out to see if there were lessons to be learned from this first reporting cycle that could be extrapolated into the next reiteration. Beyond this, there is the application of those lessons to the ongoing “business as usual” (BAU) environment. KIID production has changed substantially from the first deadlines into a very different landscape today. As reporting and data challenges build up for asset managers and their administrators, we wanted to assess if a similar trend may evolve in the reporting under AIFMD and whether such a change needs to take place.
Finally, we were looking for trends in the broader AIFMD perspective. We wanted to identify how regulators are interacting with the market and how the data received are being utilized, their relevance, and the risks that could perhaps lead to misinterpretation. Simultaneously, we were also seeking indications via the reporting experience as to how significant the distribution of non-EU products is for asset managers and how this may weigh on the debate that is likely to start soon with the delivery of European Securities and Markets Authority’s (ESMA) long-awaited advice on the future direction of the AIFMD passport and in the broader context, of Europe’s relationship with the world in the field of “alternative investments.”