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AIFMD Reporting 2016

Author John Gill

Anders Lutz

Date November 2015

Version 1.0

Status Issued

Alternative Investment Fund Management Directive Filing Process

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Summary

• AIFMD Reporting Introduction and Overview

• Common Errors 2014/15 Submissions

• Overview of 2015/2016 year’s reporting process

• New Spreadsheet Functionality

• Q&A

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AIFMD Reporting Introduction & Overview

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• Reporting requirement flows from AIFMD Directive, Delegated Regulation and ESMA instructions.

• Reporting required under Articles 3 and 24.

• Main rationale is to identify potential systemic risk; biggest focus on in-scope funds.

• The transparency reporting requirements apply to all EU AIFMs and non-EU AIFMs that market their AIFs in the EU.

• A vast majority of Funds in Gibraltar are “small” (AUM < 100 million EUR leveraged) and have annual reporting obligations.

• Authorised AIFMs have to report either bi-annually or quarterly depending on AUM. Note that Authorised AIFMs managing assets below 100 million EUR report annually in a similar fashion to registered AIFMs.

Overview

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• Dedicated AIFMD Email inbox

• Mapping of ESMA XML schema and technical specifications to GFSC Excel based reporting documents.

• Bespoke work around IT solution to convert licensee Excel data into ESMA compliant XML.

• Provide guidance to licensees on ESMA reporting requirements, technical issues, forms and general reporting queries.

• Creation of licensee database with entity identifiers.

• Updated and enhanced AIF and AIFM Excel based reporting forms (Version 2.0) for January 31st 2016 submissions.

• > 200 Entities expected to report by January 31st 2016.

Snapshot of GFSC Preparation

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Lessons Learnt 14/15

• A large number of submitters appear to have not read the ESMA technical

guidance specifications.

• Several late filers.

• Many ad-hoc solutions required and new features to the process were added in short space of time to meet filing requirements

• The FSC spent months correcting data errors and re-creating XML Files.

• Confusion over which entities actually have submitted reports.

• Complaints.

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Common Errors 2014/2015 Submissions

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• File naming conventions are important in order to structure data locally in our databases.

• Files must be saved in ffff_AIF_yyyymmdd_hhmm.xlxs format. Where ffff is the Firm or Fund identifier, yyyymmdd is the date the file is created (not the filing period) and hhmm is the time the file is created.

• AIF_Companyname_20160101

• 12345_AIF_20160101_0900

File Name

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Creation Date & Time

• A number of reports had either left this blank or used the incorrect format.

• The date (ISO 8601 extended Date Format yyyy-mm-ddThh:mm:ss) at which the file was created. It should be expressed as Coordinated Universal Time (UTC).

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• Last reporting flag set to true or not set. This is a mandatory reporting field to be filled in when the AIF has been liquidated or merged during the reporting period, true if it is the last AIF reporting file or false otherwise.

• If the last reporting flag is set to true this means that this will be the last time the AIF submits a report.

Last Reporting Flag

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• This refers to the Question number (14) for which assumption is provided. It is to be provided in numerical format and not as a text string.

• E.g Question number referred to with attached assumption description.

Question Number Assumptions

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• Each entity should have both a unique AIF identifier code and a parent AIFM national code which they come under.

• There were several cases where only one or the other was provided or AIFM codes were used instead of AIF codes and vice versa.

• Both these codes are mandatory and should be provided in their respective fields. If you are unsure of your identifier code please refer to the website or contact the GFSC directly.

• Every filer must submit at least 1 AIFM and AIF workbook

AIF/AIFM National Codes

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• If the No Reporting Flag is set to "true” this means that the file is expected to have no figures for the reporting period other than the information to identify the fund.

• This is a mandatory field that should be “false” otherwise. Any data entered past this point with the AIF no reporting flag set to “true” will give rise to XML generation errors.

No Reporting Flag

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• Master feed status drop down is a mandatory field and must be set.

• 3 statuses are admitted; master for master AIF, feeder for feeder AIF and none for other cases.

Master Feeder Status

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• There were certain important fields left blank by some firms such as:

- 48 Total Assets Under Management

- 49 Base Currency of the AIF

- 53 Total Net Asset Value of the AIF

- 50-52 FX rates (mandatory for entities that use a different base currency to the Euro).

• This error exists in other areas of the reporting file; firms are urged to check ESMA guidelines if they are unsure if fields are mandatory or not.

Mandatory Fields Left Blank

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• Where decimal places are used/required it is important to follow the ESMA technical guidelines and not go over decimal points required.

• For example field 50 requires a maximum of 4 decimal places in its FX rate. Any more will cause an error in the XML.

• This error exists in other areas of the reporting file so firms are urged to check ESMA guidelines if they are unsure the maximum amount of decimal places to use.

Additional Decimal Places

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• Aggregated value for each sub-asset type expressed in Base currency filled in without decimal places (98).

• On occasions firms used decimal places here contrary to ESMA guidance.

Aggregated Values

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• There are examples in the reporting file where ESMA specifies a maximum amount of characters, for e.g. LEI codes, BIC codes, CUSIP codes, Bloomberg codes, ISIN codes, Reuters codes etc.

• If there is an additional space (‘ ‘) at the beginning or end of a code it will fail validation for breaching the maximum amount of characters required in the specification.

• This typically happens when filers copy and paste codes, figures or values into fields.

• Please remember, no copy/paste!

Additional Spaces

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• BIC codes should be 11 characters as per ESMA guidance notes. In some cases there are existing BIC codes which are 8 characters long. In these cases the firm is required to add ‘XXX’ to the end of the code so that it becomes a valid code number.

• E.g CHASUS33 becomes CHASUS33XXX

• In some reports where filers did not know the information they needed to submit they simply entered “n/a” into the field. This is not an acceptable data answer and will not pass validation and immediately result in an error.

BIC Codes & N/A

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• When selecting ISIN under instrument code type, the fields (69-73) relating to AII (alternative investment ident.) are forbidden.

• If data is entered in AII fields, when selecting ISIN, the data will create errors in the XML generation.

ISIN & AII

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Overview of 2015/2016 year’s reporting process

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Reporting Process

AIFM/AIF Funds

Technical Specifications

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Key Dates

• November 12th & 19th 2015 – Industry workshops.

• Test cycle for firms (1 file per firms to be submitted).

• 4th December 2015 - Deadline for test file.

• 11th December 2015 – Review feedback and live release.

• 31st January 2016 – Reporting deadline.

NOV DEC JAN

Workshops/Feedback

Test Submission Deadline

Final Templates Available

Submission Deadline

12th 19th 4th 11th 31st

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New Spreadsheet Functionality

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The New Spreadsheet: Version 2.0

New Version

Built in ESMA Technical Guidance

Detail has been included to enable filers to gain a good understanding of the data to be reported in

relation to ESMA requirements.

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Question Numbers Hover over comments built into spreadsheet from ESMA guidelines.

Additional link to technical guidance question number in the spreadsheet.

Back button for convenience going back and for the from technical specs

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Validation Sheet

Link to validate spreadsheet

Name and list of errors

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Clear Validation Checks

• Once all validation checks have been cleared the user can save and close the file and prepare for it to be sent to the GFSC via email.

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Highlight Missing Validations

Mandatory fields that are missing will be highlighted in the spreadsheet

Extensive validation has been added to enable filers to check that their data is technically compliant with the ESMA guidance before submission to the GFSC.

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No Reporting Flag

When No Reporting Flag is set to TRUE the complete description block is removed

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XML Conversion

XML Conversion button

Status and file locations

XML notepad editor

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XML Example

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• Filers will need to use the new Macro Enabled (.xlsm) spreadsheets in order to benefit from the validation and customised reporting.

• Data must not be pasted into the new spreadsheets as this will overwrite the data checks and remove some of the related validation warnings.

• Filers are requested to consult the embedded ESMA guidance and check the ESMA reporting website pages where validation failures.

• Validation check in the spreadsheet must be cleared prior to sending workbook.

• Where the filer is still unable to resolve the issue should they contact the GFSC using the dedicated email account.

• XML generation is an optional step that the GFSC would encourage filers to use in order to prepare themselves for 2017 submission.

Notes

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Questions?