In January of this year, many hedge fund managers faced their first “Annex IV” (transparency reporting) filings under the AIFMD. On March 11, 2015, Hedge Fund Law Report and Advise Technologies, LLC sponsored a panel discussion in London on lessons from the first filing of specific relevance to U.K. hedge fund managers. In particular, the panel considered the recent experiences of managers in preparing for, submitting and, if necessary, amending Annex IV; FCA guidance on Annex IV obtained in a private meeting; negotiating the general lack of availability of guidance; and allocation of the cost of Annex IV reporting. For a discussion of allocating expenses in an analogous context, see “How Should Hedge Fund Managers Allocate Form PF Expenses Between Their Hedge Funds and Their Management Entities?
,” Hedge Fund Law Report, Vol. 5, No. 25 (Jun. 21, 2012). Panelists also offered a number of valuable lessons from their recent filing experiences and suggestions for facilitating future filings. The program, “AIFMD Annex IV – Lessons Learned from the January Filing,” featured Nick Jarrett, Managing Partner and Chief Technology Officer at Ivaldi Capital; Leonard Ng, Partner and co-head of the E.U. Financial Services Regulatory group at Sidley Austin; and Jeanette Turner, Managing Director at Advise Technologies. See also “Seven Tips and Lessons Learned from January 2015 AIFMD Filers
,” Hedge Fund Law Report, Vol. 8, No. 6 (Feb. 12, 2015); “HFLR-Advise Technologies Panel Explores AIFMD Marketing and Annex IV Reporting Requirements
,” Hedge Fund Law Report, Vol. 8, No. 2 (Jan. 15, 2015).