MMF Regulation: Reporting obligations to start end of Q1 2020

Context and objectives

According to Article 37 of Regulation (EU) 2017/1131 of the European Parliament and of the Council of 14 June 2017 on money market funds (Money Market Fund Regulation or MMFR), the manager of a money market fund (MMF) must report certain information to the competent authority of the MMF (as we reported at the time).

The reporting must be conducted on at least a quarterly basis or – for money market funds with assets under management of less than €100 million – on at least an annual basis. The filing of the first reports for Q1 2020 was originally set to be due in April 2020.
 

In Luxembourg

As foreseen in the EU regulation, Luxembourg issued two circulars in early February confirming that reporting will start in April on figures from Q1 2020.

In Luxembourg, the Commission de Surveillance du Secteur Financier (CSSF) issued two circulars on MMF reporting at the beginning of February:

• Circular CSSF 20/734, which aims to complement ESMA’s MMF technical reporting instructions with additional Luxembourg-specific technical details allowing managers of MMFs under the supervision of the CSSF to fulfil their reporting obligations under Article 37 of the MMFR, and 
• Circular CSSF 20/736, which implements ESMA’s guidelines on the reporting to competent authorities under Article 37 of the MMFR in Luxembourg. 

By means of the above circulars, the CSSF explicitly clarifies that the first reporting period starts from 01/01/2020 to 31/03/2020 for MMFs subject to a quarterly reporting obligation, and from 01/01/2020 to 31/12/2020 for MMFs subject to a yearly reporting obligation. Reporting should be submitted to CSSF no later than 30 days following the end of the relevant reporting period.

In Ireland

Contrary to Luxembourg, on 4 February 2020, the Central Bank of Ireland (CBI), is reported to have announced that the first filing of Q1 reports under the European MMFR shall be deferred until July 2020.

Although the objective of the deferral is to provide managers of Irish MMFs with more time to prepare the reporting infrastructure, it should be noted that the quarterly reporting under the MMFR for Q2 2020 will also be due in July 2020, meaning that both Q1 and Q2 2020 reporting under the MMFR will be due in July 2020.

The CBI will validate the reports submitted by MMF managers to ensure that those comply with the requirements set out in the MMFR. Any reports that fail the CBI’s validation would be returned and consequently have to be re-submitted by the respective MMF manager once the validation issues have been resolved.

How can Deloitte help?

Deloitte’s advisory specialists and dedicated services will help you design and implement your business strategy in light of the future evolution of the regulatory framework and market trends.

Additionally, within its Reporting Factory service, Deloitte can help with a range of solutions for the forthcoming MMF reporting tailored to your business needs.

With our Regulatory Watch Kaleidoscope service, Deloitte can also help you stay ahead of the regulatory curve to better manage and plan upcoming regulations.

Contacts

Subject matter specialists 

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