FCA provides guidance on Annex IV reporting
Representatives from the Financial Conduct Authority (FCA) provided guidance on the upcoming Annex IV reporting at a meeting sponsored by the Investment Management Association, the primary AIFM industry group in London.
According to a regulatory briefing by ConceptOne, the FCA described two options post October 2014 for filing Annex IV:
◦ Manually uploading the filing in XML format into the Gabriel reporting system; or
◦ Uploading the XML file via a "B2B" portal (ConceptONE methodology).
The FCA will only accept the ESMA XML schema v1.1 for the foreseeable future despite ESMA's release of v1.2 on May 25. Only "registered" Gabriel users will be able to upload filings.
The FCA understands that the challenge Annex IV presents is significant and anticipates some forbearance on enforcement as firms acclimate to the filing process. ConceptOne says the FCA means that the accuracy and understanding of Annex IV filers may at time contain some inaccuracies in the short term but the obligation to file remains a firm commitment.
Delegated reporting through third-party vendors is acceptable; however, AIFMs remain responsible for the filing and the FCA will expect internal expertise and familiarity with the process and specific filing.
This point was made clear to ConceptOne in a meeting the firm recently had with the FCA - they expect to see firms develop, implement and maintain regulatory infrastructure for AIFMD compliance generally, including but not limited to Annex IV reporting.
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