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Alternative Market Briefing

Belgium and Luxembourg regulators require non-EU feeder AIFs to report on master fund

Wednesday, April 29, 2015

Komfie Manalo, Opalesque Asia:

The Belgian and Luxembourg regulators now require non-EU alternative investment fund managers (non-EU AIFMs) to make "Annex IV" reports in respect of master funds if one or more of that master fund’s feeder funds are marketed in Belgium and Luxembourg, respectively, under the national private placement regimes.

This obligation towards Luxembourg’s financial services regulator Commission de Surveillance du Secteur Financier (CSSF) and its Belgian counterpart, Financial Services and Markets Authority (FSMA), is in effect as of the Q1 2015 report that has to be submitted by 30 April 2015.

According to Rolf Bachner, managing director of EMEA funds product manager at BNY Mellon, "AIFMD defines a feeder as a fund that invests at least 85% of its assets in a master. The directive requires that documentation on feeder AIFs include information on the master as well. Now this information requirement is carried through into the regulatory reporting and extended to funds distributed under the private placement regimes in the two countries."

Non-EU AIFMs will have to put in place systems and procedures to complete the Annex IV reports in respect of master AIF-level data and report the same by the end of April 2015, reports ......................

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