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Open access, Annex IV, and how to stay on top of regulatory changes

Open access, Annex IV, and how to stay on top of regulatory changes  

With the release of open-source, direct access tools like the Luxembourg CSSF's S3 API, you might be tempted to consider building your own dissemination funnel. Have you considered the broader implications of a decision that will significantly impact your firm’s operations?  

If AIFMD Annex IV reports are the only documents you need to transmit, the volume of your funds is limited and they are solely distributed in Luxembourg, then direct access is a free and viable option. For a broader range of funds distributed across borders or for managers dealing with multiple report types, you'll need additional solutions to optimise the workloads and ensure quality and consistency of your output beyond solely AIFMD Annex IV reporting. This will then require the following core functions: 

  • Regulatory scanning 
  • Report production at scale 
  • Report filing to the CSSF in Luxembourg 
  • Fund information distribution to several recipients in other jurisdictions. 

Before making the decision, consider the broader context of your regulatory and operational reality. 

Five questions to ask before selecting your model 

1. Do I currently have the IT resources required to be able to use solely direct access?  

Transitioning to direct access requires building and maintaining your own transmission funnel. This can significantly strain your IT department, potentially diverting resources from core business activities. With FE fundinfo, these technical aspects are handled for you, both for current and future iteration of reporting requirements.  

2. How will I manage support issues?  

Open-source solutions such as S3, created in the spirit of self-serve, tend to lack dedicated support. Your team will need to troubleshoot issues independently. FE fundinfo offers expert support and guidance throughout the regulatory filing process. Read our case study on the support we provided to an AIFM ensuring their business continuity with e-file.  

3 . Does direct access tool handle the production of AIFMD reports, or just transmission?  

Direct access is a transmission tool. FE fundinfo offers both AIFMD report production and transmission, providing a solution that reduces the risk of errors and inconsistencies.  

4. How will I adjust to regulatory updates?  

With direct access, you're responsible for staying informed about regulatory changes and updating your processes accordingly. FE fundinfo's team continuously monitors the regulatory landscape, adapting our solutions to ensure ongoing compliance.  

5. Will switching affect my ability to track historical submissions and approvals?  

An open source API such as S3, does not offer comprehensive tracking and reporting capabilities. FE fundinfo provides a robust dashboard for monitoring submission status, regulatory feedback and historical data, which is crucial for audit trails and regulatory oversight.  

Beyond transmission - advantages of a holistic approach 

At first glance, direct access could be seen as an attractive  solution. But its limited scope – and the technical burden it creates – make it an inadequate option for many firms. Without dedicated support, it necessitates independent troubleshooting and maintenance in addition to up-front development. 

Navigating the world of fund data management and regulatory compliance requires vigilance, dedication and scalable tools. As a trusted provider of data, transactions, dissemination and more, FE fundinfo goes beyond simple document transmission with a holistic, multi-jurisdictional solution that addresses every aspect of your regulatory needs. 

Unparalleled expertise in data and calculations

At the core of our offering is our deep expertise in fund data and calculations. We understand that accurate, timely data is the foundation of effective regulatory compliance.  

Comprehensive report templates and production 

FE fundinfo excels in creating and maintaining up-to-date report templates for a wide range of regulatory requirements, including UCITS, PRIIPs, and AIFMD Annex IV reports. Our report production service leverages these templates along with your validated data to generate accurate, compliant reports.  

Seamless transmission and filing 

Once reports are produced, our e-file platform ensures smooth transmission to the relevant regulatory authorities. With secure connections to over 60 national competent authorities across Europe, the UK and Asia, we facilitate the transmission of 3.5 million documents annually. Our extensive coverage includes 14 different regulatory submissions, from notifications and periodic reports to KID updates and AIFMD regulatory reporting. 

Deep regulatory experience 

AIFMD requirements have already changed since first rolling out. Indeed, regulatory frameworks and the underlying reports we produce for our clients change regularly. Since its inception in 2018, PRIIPS KID has undergone two major overhauls, with another one on the horizon, which didn’t stop us from delivering 450k KID documents to 1 January 2023 deadline. Templates such as EPT, EMT and EET have seen a whooping 12 iterations in just three years. We remain unfazed by these changes. Our team is committed to understanding the evolving regulatory landscape and continuously monitors for changes. We proactively adjust our offerings accordingly to ensure that our solutions are always up-to-date.  

Looking beyond Luxembourg 

While S3 addresses Luxembourg-specific needs, FE fundinfo's solution caters to the cross-border reach of your funds. We support Luxembourg-domiciled funds distributed in 80 countries worldwide, ensuring you're covered no matter where your business takes you. 

Choose continuity and expertise 

By continuing to partner with FE fundinfo, you're not just choosing a transmission service – you're investing in a relationship with a team that understands the nuances of fund regulation across markets. Our expertise allows you to focus on your core business while we handle the complexities of regulatory compliance with a comprehensive platform.  

While new tools like S3 may seem appealing, they represent a fraction of what's needed for true regulatory compliance. FE fundinfo's holistic solution, combining report production and transmission for AIFMD, UCITS, PRIIPs and more, offers a robust, efficient and future-proof approach to managing your regulatory obligations. 

  • Alex Donati FE Fundinfo
  • Oliver Steen FE Fundinfo

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