AIFM / AIFMD Annex IV Reporting
Released in 2020 to respond to the AIFMD Annex IV reporting requested by the ESMA. Neat & nifty solution tailored for Luxembourg fund managers which focus on preserving the confidentiality of their investors
RGen AIFM - General
RGen AIFM is a Luxembourg-made solution tailored for the Luxembourg AIFM Managers and institutions for the filings of the AIFMD Annex IV reports.
The AIFM Directive (Alternative Investment Fund Managers Directive) is a European directive that has introduced harmonised rules with which alternative investment fund managers must comply since 22 July 2013.
The scope of the AIFM Directive is broad, contrary to what the letter 'A' of 'alternative' might suggest. The AIFM Directive applies in principle to all managers of one or more alternative investment institutions, i.e. collective investment vehicles that are not undertakings for collective investment in transferable securities (UCITS).
- Private equity funds
- Hedge funds
- Infrastructure funds
- Real estate funds
- Equity funds
- Bond funds
... fall under AIFM supervision.
The AIFMD was implemented to better regulate alternative investments that were left largely unchecked prior to the 2008-09 global financial crisis. The directive aims to protect investors as well as reduce some of the systemic risk that these types of funds can pose to the EU and its economy.
The first aspect of RGen AIFM is a response to a condition : preserve confidentiality. Most solutions on the market are of SAAS type, based on a third-party mutualised server. Such technology do not marry well with data confidentiality but also further expose them to security threads. The best method to preserve data confidentiality is to limit the number of people having access to them.
In practice :
- RGen AIFM is an offline application, it does not requires access to internet
- All the data handled (in the templates/reports) are protected under our customer's IT infrastructure
- No third party technical provider, no mutualized external platform
- Solution is 100% managed and operated internally
- U IT provides technical support for installation & configuration and can also provide dedicated business support to fill or correct the reports
The second aspect is the focus on the Luxembourg AIFMD reporting. This dedication and limitation to the Luxembourg market allows U IT to outperform due to our local know-how.
Topics like :
- Local CSSF guidelines to respect for sending the reports
- The obligation to use one of the 2 authorized secure channels for filings
- The right handling & interpretation of the possible feedbacks received from CSSF
- The interpretation of CSSF emails with report's corrections or cancelation requests
... are typical to Luxembourg and fully mastered by U IT.
Characteristics and features of the solution are described in detail in the Technical page or in the Overview (PDF) document which visually presents the solution.
Choosing U IT
The advantage to use our solution is closely linked to our expertise in the Luxembourg legal reporting. We ensure the following :
- to grant dedicated advises and instructions
- to help you to fill and send your first reports, quickly if necessary
- to share our knowledge and provide the necessary help until you master this reporting
- to put you in touch with the right department & people at the CSSF
- for the filings, we can help you to setup your secure channel (SOFiE) or propose you to use our filing service
Contact us if you need more information
RGen AIFM - Technical
The RGen AIFM solution is composed of 2 elements : excel templates for the capture interface (manual data input) and a converter named RGen AIFM.
We opted for a 2 parts solution which brings the following advantages :
- More flexibility, the filling task can be granted to a speciliased colleague or a third party expert
- Splitting the task allows the appliance of the 4 eyes principle
- Ease any help or support request to fill a template or to perform correction requested by the ESMA or CSSF
The ESMA released 2 standards Excel template to fill for AIFMD, they can be downloaded at this link
We released an improved version of the 2 templates early 2021. Mid 2022 we released a new and more definitive version (v2.0) - open the above PDF for a visual
The main characteristics of our latest templates are :
- Neat and nifty interface, the templates were strongly customised to be clear & intuitive for users
- Many support information added: help screens, cell's comment for each items, inline help, external links
- Listed values (drop box) for all fields requirying a precise input
- All cells contain a data validation which prevent to enter inadequate values
- Extra functions were added and further should be added in the future releases
RGen AIFM converter
RGen AIFM was developped considering users but also IT :
- For Users : intuitive, smart and easy-to-use
- For IT : portable, small (in size), easy to install or to package under Citrix, executable from a network/share drive, batch mode, extra support functions, clear logs
- Strong data validation engine including all the rules set by the ESMA + extra controls & calculations ensuring data consistency
- Generate the XML reports under ZIP with the requested filename, ready to be sent
There are 2 levels of automation possible : automating the capture of the data and automating the report creation/generation.
Automating data capture RGen AIFM is able to receive in entry a raw (flat) data file and convert it to the final XML report. But the complexity of the AIFMD reporting, more particularly the AIF report, renders it from difficult to impossible. The task for the IT department in charge of extracting the right data required to fill all the 300+ fields of the report which must respect a preliminary great amount of constraints is huge. Such project should be strongly discussed prior deciding to engage in it
Another element to take into consideration is the frequency of these reports : from 1 to 4 per year. Except if one customer has to report for many entities, the cost to automate the capture part of this reporting will probably not be profitable
Automating report's conversion The conversion process from a filled excel template to the XML report can be automated, it can be configured to semi-automated (on-demand) or to fully automated
With semi-automation, users must 2x click an icone to start the conversion process, preventing them to use the manual interface.
In full automation, users just have to deposit (copy) the filled template in a specific directory, RGen AIFM, installed on a server, which runs periodically, will process it. Such configuration is usually installed within a broader workflow including the automation of the encryption & sending of the reports
In both cases RGen AIFM can send an automatic email in case of error (or success) during conversion
RGen AIFM - Timeline
- 2022-08 - Website update - RGen AIFM page added
- 2022-07 - Major update, release of v2.0 of the templates
- 2022-06 - Release v1.2 of RGen AIFM
- 2022-02 - Release v1.1 of RGen AIFM
- 2022-01 - Release v1.3 of templates
- 2021-10 - Release v1.2 of templates
- 2021-05 - Release v1.1 of templates
- 2021-02 - Release v1.0 of RGen AIFM and v1.0 of templates
- 2020-10 - First reports sent in production
- 2020-10 - First beta version of RGen AIFM, first reports generated