AIFMD Reporting And Filing Deadlines

On January 10th 2014, the CSSF issued an updated FAQ (the "FAQ") on alternative investment fund managers ("AIFMs") and on January 14th it released Circular 14/581 on new reporting obligations for AIFMs.

These documents, not only shed light on the frequency, content and channel of transmission of the reporting to be done by AIFMs and alternative investment funds ("AIFs") pursuant to the law of July 12th 2013 on alternative investment fund managers but they also clarify some specific reporting and filing deadlines.

NEW DEADLINE

Pursuant to the FAQ (Question 8 (c ) (i)) all AIFMs benefitting from the grandfathering provisions and which need to request an authorisation are invited to submit their application request to the CSSF as soon as possible and by April 1st 2014 at the latest. It shall also be reminded, on the product side, that the CSSF had already clarified that all Part II Funds, SIFs and SICARs benefitting from the transitional provisions, are invited to submit to the CSSF, also by April 1st 2014, a file containing information on how they intend to comply with the product rules relating to them (i.e. rules on the annual report, valuation, disclosure to investors and depositary) (Question 8 (c) (ii)).

REPORTING START DATE

Pursuant to the FAQ (Question 14 (c)), AIFMs are informed of the effective date of their status as authorised or registered AIFM by the CSSF. It is this date that shall be relevant for determining the start date for reporting.

The CSSF has set out a calendar of reporting in the FAQ and clarified that reporting shall commence as from the first day of the quarter following their authorisation/registration. Thus for an AIFM authorised on January 16th 2014 and subject to quarterly reporting the first...