AIFMD Review 2020

Questions for members

Thank you to those who attended the Member roundtable on 16th December.

We would be grateful if you could please take 5 minutes to complete this survey to gather information for the AREF response to the AIFMD review.

Question Title

* 1. (AIFMD Review Question 1) What is your overall experience with the functioning of the AIFMD legal framework?

Very satisfied

Satisfied

Neutral

Dissatisfied

Very dissatisfied

Don’t know / no opinion / not relevant

Question Title

* 2. (AIFMD Review Question 2) Do you believe that the effectiveness of the AIFMD is impaired by national legislation or existing market practices?

Fully agree

Somewhat agree

Neutral

Somewhat disagree

Fully disagree

Don’t know / no opinion / not relevant

Please explain your answer to Q2 with examples and data to substantiate it, if possible:

Question Title

* 3. (AIFMD Review: Question 61) Are the supervisory reporting requirements as provided in the AIFMD and AIFMR’s Annex IV appropriate?

Fully agree

Somewhat agree

Neutral

Somewhat disagree

Fully disagree

Don’t know / no opinion / not relevant

Please explain your answer to Q3. Would you want Annex IV to be more appropriate for real estate? Would you want a reporting section for real estate funds?

Question Title

* 4. (AIFMD Review Question 69) Does the AIFMR template effectively capture links between financial institutions?

Yes

Don’t know / no opinion / not relevant

Please explain your answer to Q4. If you responded “No”, what additional reporting should be required to better capture inter-linkages between AIFMs and other financial intermediaries?

Question Title

* 5. (AIFMD Review Question 70) Should the fund classification under the AIFMR supervisory reporting template be improved to better identify the type of AIF?

Yes

Don’t know / no opinion / not relevant

Please explain your answer to Q5. If you answered “Yes”; should the AIF classification be improved by permitting multiple choice of investment strategies in the AIFMR template; adding additional investment strategies or some other way? If you do believe it cannot be improved, should a portfolio breakdown be provided to the supervisors?

Question Title

* 6. (AIFMD Review Question 71) What additional data fields should be added to the AIFMR supervisory reporting template to improve capturing risks to financial stability:

Please select as many answers as you like

Value at Risk (VaR)

Additional details used for calculating leverage

Additional details on the liquidity profile of the fund’s portfolio

Details on initial margin and variation margin

The geographical focus expressed in monetary values

The extent of hedging through long/short positions by an AIFM/AIF expressed as a percentage

Liquidity risk management tools that are available to AIFMs

Data on non-EU master AIFs that are not marketed into the EU, but which have an EU feeder AIF or a non-EU feeder marketed into the EU if managed by the same AIFM

The role of external credit ratings in investment mandates

LEIs of all counterparties to provide detail on exposures

Sustainability-related data, in particular on exposure to climate and environmental risks, including physical and transition risks (e.g. shares of assets for which sustainability risks are assessed; types and magnitudes of risks; forward-looking, scenario-based data)

Other

Please explain your answer(s) to Q6.

Question Title

* 7. (AIFMD Review Question 72) Should additional data fields be added to the AIFMR supervisory reporting template to better capture AIF’s exposure to leveraged loans and CLO market?

Please explain your answer to Q7.

Question Title

* 8. (AIFMD Review Question 73) Should any data fields be deleted from the AIFMR supervisory reporting template?

Yes

Don’t know / no opinion / not relevant

Please explain your answer to Q8.

Question Title

* 9. (AIFMD Review Question 74) Is the reporting frequency of the data required under Annex IV of the AIFMR appropriate?

Yes

Don’t know / no opinion / not relevant

Please explain your answer to Q9.

Question Title

* 10. (AIFMD Review Question 75) Which data fields should be included in a template requiring AIFMs to provide ad hoc information in accordance with Article 24(5) of the AIFMD during the period of a stressed market in a harmonised and proportionate way?

Please explain your answer to Q10.

Many thanks for taking the time to complete this survey.

Question Title

* 1. (AIFMD Review Question 1) What is your overall experience with the functioning of the AIFMD legal framework?

Question Title

* 2. (AIFMD Review Question 2) Do you believe that the effectiveness of the AIFMD is impaired by national legislation or existing market practices?

Question Title

* 3. (AIFMD Review: Question 61) Are the supervisory reporting requirements as provided in the AIFMD and AIFMR’s Annex IV appropriate?

Question Title

* 4. (AIFMD Review Question 69) Does the AIFMR template effectively capture links between financial institutions?

Question Title

* 5. (AIFMD Review Question 70) Should the fund classification under the AIFMR supervisory reporting template be improved to better identify the type of AIF?

Question Title

* 6. (AIFMD Review Question 71) What additional data fields should be added to the AIFMR supervisory reporting template to improve capturing risks to financial stability:Please select as many answers as you like

Question Title

* 7. (AIFMD Review Question 72) Should additional data fields be added to the AIFMR supervisory reporting template to better capture AIF’s exposure to leveraged loans and CLO market?Please explain your answer to Q7.

Question Title

* 8. (AIFMD Review Question 73) Should any data fields be deleted from the AIFMR supervisory reporting template?

Question Title

* 9. (AIFMD Review Question 74) Is the reporting frequency of the data required under Annex IV of the AIFMR appropriate?

Question Title

* 10. (AIFMD Review Question 75) Which data fields should be included in a template requiring AIFMs to provide ad hoc information in accordance with Article 24(5) of the AIFMD during the period of a stressed market in a harmonised and proportionate way?Please explain your answer to Q10.

* 6. (AIFMD Review Question 71) What additional data fields should be added to the AIFMR supervisory reporting template to improve capturing risks to financial stability:

Please select as many answers as you like

* 7. (AIFMD Review Question 72) Should additional data fields be added to the AIFMR supervisory reporting template to better capture AIF’s exposure to leveraged loans and CLO market?

Please explain your answer to Q7.

* 10. (AIFMD Review Question 75) Which data fields should be included in a template requiring AIFMs to provide ad hoc information in accordance with Article 24(5) of the AIFMD during the period of a stressed market in a harmonised and proportionate way?

Please explain your answer to Q10.