Apr. 13, 2017
Apr. 13, 2017
Private Fund Managers Should Continue Aggressive Compliance Efforts Despite New Administration
FCA Amends Its Position on Annex IV Reporting: U.K. and Non-EEA Managers, Including U.S. Managers, Must Now Report Holdings at Master Fund Level
Last summer, the U.K. Financial Conduct Authority (FCA) set out proposals for a significant change to the Annex IV reporting requirements under the Alternative Investment Fund Managers Directive. The FCA proposed amendments to its handbook that would expand the Annex IV reporting obligations of certain alternative investment fund managers (AIFMs) located in the U.K., as well as outside of the European Economic Area (EEA), that market non-EEA alternative investment funds (AIFs) to U.K. investors via the country’s national private placement regime. See “U.S. Managers Marketing to U.K. Investors Could Face Ballooning Reporting Burdens Under Proposed Rule” (Jul. 28, 2016). The new rules would specifically require those AIFMs to file Annex IV reports at the master AIF level; whereas, historically, the FCA had limited reporting by those AIFMs to the feeder AIF level. See “U.K. FCA Guidance Confirms Simplified Transparency Reporting for Certain Private Placements of Master-Feeder Funds” (Nov. 20, 2014). In a guest article, Devarshi Saksena and Lucian Firth, partner and managing associate, respectively, at Simmons & Simmons, consider the implications of this amendment, including what has changed and whom it affects, and provide practical guidance on how firms can comply with the new reporting requirements. For additional insight from counsel at Simmons & Simmons, see “Seward & Kissel Private Funds Forum Offers Practical Steps for Fund Managers to Address HSR Act Enforcement, Tax Reforms, Brexit Uncertainty, MiFID II, Cybersecurity and Side Letters” (Oct. 20, 2016).
Read full article …New Rule Offers Managers a Way to Raise Capital in China
Credit Suisse Investor Survey Finds Steady Demand for Hedge Funds and Growing Demand for Less-Liquid Products
Failure to Disclose Fees Received From Third-Party Broker-Dealers May Result in Significant Penalties for Investment Advisers
FCA Report Details the Failure of Actively Managed Funds to Eclipse Benchmarks Despite High Investor Charges and Poor Cost Controls (Part Two of Two)
Mintz Levin Adds Corporate and Securities Partner in New York
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To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.