MFA Submits Comments to ESMA in Response to AIFMD Reporting Guidelines

MFA submitted a comment letter to ESMA in response to ESMA’s consultation paper on AIFMD reporting guidelines.  In the letter, MFA asked ESMA to: (1) clarify or confirm a number of specific items in the reporting form; (2) develop a harmonized approach to reporting across EU Member States; (3) limit the scope of required information to what was required by the European Commission in the Level 2 Delegated Regulations; (4) permit AIFMs to report information on the basis of the best data available, given the short time periods for filing quarterly reports; and (5) amend the proposed guidelines with respect to master/feeder funds, funds of funds, and other tiered funds to avoid duplicative reporting requirements.