On 18 May 2018, the Banque Centrale du Luxembourg (BCL) released a circular to inform non-regulated alternative investment funds (AIFs) of their reporting obligations under regulation ECB/2013/38 concerning statistics on the assets and liabilities of investment funds as well as the ECB guideline on monetary and financial statistics (ECB/2014/15).
Collection of statistical data
The Circular implements a statistical reporting for non-regulated investment funds.
As a first step, in order to complete the identifying data, non-regulated AIFs must provide the BCL with additional data within a week starting from their first day of activities.
Subsequently, the non-regulated AIFs will have to provide the following reports:
a) S 1.6 « Information on valuation effects on the balance sheet of non-MMF investment funds
b) Monthly security-by-security report of investment funds
c) S 2.13 «Quarterly statistical balance sheet for non-MMF investment funds»
The whole set of instructions for the statistical reporting is published and can be downloaded from the BCL's website under "Regulatory reporting".
The respective deadlines for submission of the required reports are available on the website of the BCL.
Exemptions from reporting obligations
The BCL grants exemptions to some non-regulated AIFs from submitting their monthly and quarterly reporting if their total assets are below a threshold of EUR 500 million. Those funds benefiting from the exemption must submit their annual balance sheet to the BCL within 15 days following the certification of the annual accounts.
Implementation of the new collection
A two-step process should be followed:
1) The transmission of the completed form concerning the identifying data and of the latest available balance sheet is due before 31 May 2018, by e-mail to reporting.opc@bcl.lu.
2) For those funds without exemption, the quarterly report (see above mentioned report c)) and the monthly report (see report b)) for the September 2018 reference period must be submitted before 26 October 2018. If applicable, the monthly report S 1.6 (see report a)) for the October 2018 reference period must be submitted before 29 November 2018.
The full test of Circular is available at the following link.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.