On January 25, the UK Financial Conduct Authority (FCA) published amendments to its rules on Annex IV reporting under the EU Alternative Investment Fund Managers Directive (AIFMD). The amendments will affect non-European Economic Area (EEA) Alternative Investment Fund Managers (AIFMs) that market feeder Alternative Investment Funds (AIFs) in the United Kingdom under the United Kingdom’s implementation of the Article 42 AIFMD, which allows such non-EEA AIFMs to market their funds in the United Kingdom in accordance with the UK’s national private placement regime.

After the amendments go into effect, AIFMs that report Annex IV information for their feeder AIFs on a quarterly basis will be required to report quarterly information regarding the feeder AIF’s master AIF, notwithstanding that the master AIF is not itself marketed in the United Kingdom.

Furthermore, UK authorized managers that are subject to the quarterly reporting requirement also will need to complete Annex IV reporting for each non-EEA fund that is not marketed in the EEA. UK managers that are subject to the reporting requirement for non-EEA master funds (either because the feeder fund is an EEA fund or is a non-EEA fund that is marketed in the EEA) will only need to continue to complete Annex IV reporting for the master fund if they are also subject to the quarterly reporting requirement.

The revised requirements go into effect on June 29, requiring firms to report under them by August 15 for a fund of funds, and July 31 for all other fund types.