AIFMD FAQ

How should AIFMs report to the UK?

XML

Our software automatically handles the slightly different XML format used by the FCA’s RegData.

Assumption - Question Number (AIF and AIFM Question 14)

The FCA’s RegData uses different question numbers than the ESMA. Any ESMA question numbers are automatically cross-referenced to FCA question numbers by our software.

Regions (AIF Questions 78-93)

The FCA wants reports over slightly different regions than the ESMA. Matterhorn strives to be able to use the same input data for reporting to multiple countries. To accommodate this, the software automatically reports data in the corresponding FCA region when reporting to the UK.

Postions on our template with Region (AIF 78-93):	And Currency (AIF 128):	Are reported to the UK as:	Change
Africa		Africa	No
Asia and Pacific (other than Middle East)		Asia and Pacific (other than Middle East)	No
Europe (other than EEA)	GBP	UK	Yes
Europe (other than EEA)	Non-GBP	Europe (other than UK)	Yes
Europe (EEA)		Europe (other than UK)	Yes
Middle East		Middle East	No
North America		North America	No
South America		South America	No
Supranational / multiple region		Supranational / multiple region	No

Aggregated value percentage (AIF Questions 99 and 109)

The FCA’s RegData has a validation that can cause rejection of valid data for very small aggregated value percentages. The answers stated below mention thresholds of 0.1% and 0.5%. Our software uses a threshold of 0.5% because we found rejections using 0.1%.

FCA’s RegData Error Message: “Conditional: The ratio between Principal Exposure Aggregated Value Amount and Percentage must be consistent for all exposure entries”

Update to AIFMD Annex IV transparency reporting and GABRIEL - Page 18 [Date Unknown]:

Common Validation Error:

The ratio between Principal Exposure Aggregated Value Amount and Percentage must be consistent for all exposure entries.

Further Information:

Very small aggregated value percentages (less than 0.5% of AUM) may cause rejection of otherwise valid data. This is because the rounding error introduced by the mandated 2dp precision becomes significant when back-calculating the denominator for validation purposes for very small percentages. This issue can be avoided by omitting any lines for aggregated values this small because 0.5% of AUM can neither be described as ‘Principal’ nor ‘Most important’ replacing them with ‘NTA’ or ‘NTA_NTA’ blank entries as appropriate - this is entirely legitimate and within the spirit of the question. Please also see the below calculation for an example of how to calculate this.

FCA AIFMD Q&A - Answer 37 [6 October 2014]:

b) Principal Exposure and Most important portfolio concentration aggregated value validation

(i) Very small aggregated value percentages (less than 0.1% of AUM) may cause rejection of otherwise valid data. This is because the rounding error introduced by the mandated 2dp precision becomes significant when back-calculating the denominator for validation purposes for very small percentages.

(ii) This issue can be avoided by omitting any lines for aggregated values this small, replacing them with ‘NTA’ or ‘NTA_NTA’ blank entries as appropriate. Because 0.1% of AUM can neither be described as ‘Principal’ nor ‘Most important’ this is entirely legitimate and within the spirit of the question.

Dominant Influence (AIF Questions 131 and 136)

The FCA’s RegData has a validation that causes rejection of Private Equity funds (AIF Question 57 is “PEQF”) without any Dominant Influence records. In that case, our software automatically adds a dummy DOMINANT_INFLUENCE record with a company name “Not Applicable”.

FCA’s RegData Error Message: “Conditional: Dominant influences should be specified for private equity funds”

Sub-asset type (AIF Questions 65, 96, 121 and 125)

The FCA has a few different Sub-asset types than the ESMA (only concerning Sovereign bonds). We are working on automatically converting them. It is not done yet, so please give us a call if this concerns your fund.