MFA Submits Comments to ESMA in Response to AIFMD Reporting Guidelines

MFA submitted a comment letter to the European Securities and Markets Authority ("ESMA") in response to ESMA's consultation paper on the Alternative Investment Fund Managers Directive ("AIFMD") reporting guidelines. In the letter, MFA asked ESMA to: (1) clarify or confirm a number of specific items in the reporting form; (2) develop a harmonized approach to reporting across EU Member States; (3) limit the scope of required information to what was required by the European Commission in the Level 2 Delegated Regulations; (4) permit AIFMs to report information on the basis of the best data available, given the short time periods for filing quarterly reports; and (5) amend the proposed guidelines with respect to master/feeder funds, funds of funds, and other tiered funds to avoid duplicative reporting requirements.

See: MFA Comment Letter.