Key Pain Points in AIFMD Annex IV Reporting and Proven Strategies for Surmounting Them

Like Form PF, the consolidated AIFMD reporting template – commonly referred to as “Annex IV” – requires hedge fund managers to make consistent and persuasive sense out of voluminous and disparate data.  Best practices for Annex IV reporting are emerging; managers’ experience with Form PF provides an analogous but incomplete precedent.  In an effort to identify the chief challenges for hedge fund managers presented by Annex IV, and workable strategies for negotiating those challenges, the Hedge Fund Law Report recently interviewed Jeanette Turner, Managing Director and General Counsel at Advise Technologies, LLC.  Our interview covered, among other topics, the top three pain points felt by hedge fund managers in preparing Annex IV; the different experiences of European Economic Area (EEA) and non-EEA managers; how firms are handling the one-month deadline; the extent to which Form PF guidance is applicable to Annex IV; whether information reported in Annex IV will be made public; how regulators will use that information; key upcoming deadlines; differences in Annex IV reporting for hedge and private equity fund managers; the viability of reverse solicitation; and the continuing (but potentially sunsetting) applicability of national private placement regimes.  This interview was conducted in connection with an AIFMD panel discussion to be held on December 2, 2014 at the Harvard Club of New York City, from 8:30 a.m. to 10:30 a.m.  Turner will participate in that discussion, and she will be joined by John Sampson, Executive Director at Ernst & Young; Richard Webley, Head of Business Advisory Services for Americas, Citi Investor Sales and Relationship Management; and Simon Whiteside, Partner in the London office of Simmons and Simmons.  To attend, please contact RSVP@AdviseTechnologies.com or visit rsvp.AdviseTechnologies.com.  For additional insight from: Turner, see “A Practical Comparison of Reporting Under AIFMD versus Form PF,” Hedge Fund Law Report, Vol. 7, No. 41 (Oct. 30, 2014); Sampson, see “Eight Key Elements of an Integrated, Efficient and Accurate Hedge Fund Reporting Solution,” Hedge Fund Law Report, Vol. 7, No. 43 (Nov. 13, 2014); Webley, see “Lessons Learned by Hedge Fund Managers from the August 2012 Initial Form PF Filing,” Hedge Fund Law Report, Vol. 5, No. 43 (Nov. 15, 2012); and Whiteside, see “U.K. FCA Guidance Confirms Simplified Transparency Reporting for Certain Private Placements of Master-Feeder Funds,” below, in this issue of Hedge Fund Law Report.

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