Global Regulatory Roundup For Hedge Fund Managers – Q1 2014 (Citi)

April 2014

KEYWORDS: Hedge Fund Regulation, regulatory requirements, FATCA, EMIR, IRS, asset managers, Hedge Fund Managers, FCA, CFTC, SEC, European Union, European Parliament, Cayman Islands, United Kingdom, ISDA



  • Citi

Some Key Takeaways for Q1:
• Broader Definition of “Knowledgeable Employee”: More hedge fund employees may be able to participate as an investor in your fund.
• FATCA: The IRS just announced that the April 25th deadline for fund managers to register their offshore funds and offshore master funds with the IRS and obtain GIIN #s has been extended to May 5th. This 10-day extension buys fund managers some extra time to be included on the first FFI List if they meet the new May 5 registration deadline. Have you applied for a GIIN # and appointed a Responsible Officer to comply with FATCA?
• EMIR: If applicable, apply for your LEI # for EMIR reporting if you have not done so already.
• SEC Examinations: If you are an RIA and have not been examined by the SEC in the past 3+ years, be prepared that you may be up for an exam in 2014.
• IRS: The IRS extended the duration of Forms W-8 that would have expired on December 31, 2013 to December 31, 2014.

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