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AIFMD FAQ

Should AIFMs report cash?

Yes.

How does this translate to the Matterhorn template?

Just add entries for cash to the POSITION records. All the template questions mentioned in the ESMA AIFMD Q&A’s below are created automatically from those POSITIONS records.

Cash is reported by using the following Sub-Asset Type in a POSITION record.

Sub-Asset Type CodeSub-Asset Type
SEC_CSH_OTHCOther cash and cash equivalents (excluding government securities)

Relevant questions from Section III "Reporting to national competent authorities under Articles 3, 24 and 42" of the ESMA AIFMD Q&A:

Question 63 [last update 12 May 2015]:

Should AIFMs take into account cash and cash equivalents for the purpose of the main instruments in which the AIF is trading (questions 64 to 77 of the consolidated reporting template), the principal exposures of the AIF (questions 94 to 102 of the consolidated reporting template) and the five most important portfolio concentrations (questions 103 to 112 of the consolidated reporting template)?

Answer 63:

Yes.

Question 15 [last update 25 March 2014]:

Is cash resulting from repurchase agreements included in the amount of cash and cash equivalents to be reported by AIFMs under questions 121-124 [Individual Exposures]?

Answer 65:

Yes. When reporting information on cash and cash equivalents, AIFMs should include all amounts of cash held, including as a result of repurchase arrangements.

Question 43 [last update 30 September 2014]:

Should AIFMs include cash accounts when reporting information on the total number of open positions (question 218 of the consolidated reporting template for AIF specific information)?

Answer 43:

Yes, AIFMs should take into account all cash accounts that exist.

Question 46 [last update 30 September 2014]:

How should AIFMs treat bank overdrafts for the purpose of information on individual exposures (questions 123 and 124 of the consolidated reporting template)?

Answer 46:

AIFMs should treat bank overdrafts as short positions in ‘Cash and Cash Equivalent’.

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