Regulatory reporting services | CRS | FATCA

Keeping up with regulatory reporting obligations can be complex and onerous. Our specialist teams operate in various financial centres and understand the regulatory reporting process. We can support your business by covering end-to-end regulatory reporting, from registration to gathering data, and submitting reports through our technology platform.

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Key services include:

PRIIPS

Annex IV and Annex V

Form PF

Form ADV

Form 13F

Form 13H

The Foreign Account Tax Compliance Act (“FATCA”) is a US law aimed at reducing tax evasion by US citizens and residents using offshore assets and accounts. FATCA requires reporting on two items:

U.S. taxpayers must report on certain foreign financial accounts and offshore assets
Foreign Financial Institutions (“FFIs”) must report on financial accounts held by U.S. taxpayer or foreign entities in which U.S. taxpayers hold a substantial ownership interest. If FFIs do not comply with FATCA, they will be subject to a 30% withholding tax penalty on certain U.S. sources of income

With extensive understanding of both US tax requirements and local regulations elsewhere in the world, we are perfectly placed to assist you with FATCA compliance.

Services include:

Obtaining the Global Intermediary Identification Number (“GIIN”) which is needed to demonstrate FATCA compliance in order to avoid any withholding penalties
Classifying investors tax status based on documentation provided. In instances whereby there are indicators of US place of birth then we will request, in addition to the self-certification, a copy of the investor’s certificate of loss of nationality or a reasonable explanation as to why the investor does not have such a certificate
Contacting investors where there is insufficient data to determine US status and where applicable request self-certifications in order to determine US status
Performing a full review of investors on December 31st each year to identify any change of circumstances. The reviews will focus on US status and US indicia to ensure that reporting on any new investors is accurate and any updated information obtained for existing investors is captured prior to reporting. Accounts shall be treated as US reportable accounts if after the application of due diligence procedures, the status of the account is still ambiguous
Reporting on accounts that are classified as ‘recalcitrant accounts’ post the due diligence reviews
Reporting on all accounts deemed to be held by a US person or entity as per the provisions of the IGA to the relevant local tax authority within the specified reporting deadlines using the FATCA XML Reporting Schema
Acting as the principal point of contact through one of our employees
Keeping a record of the documents as per the regulatory provisions and provide report to the board of the company

The Common Reporting Standard (“CRS”) is a set of global standards for the automatic exchange of financial account information which impacts on the information gathered from every investor and account holder. CRS is designed to support and give effect to the Automatic Exchange of Information (“AEOI”) which is a globally coordinated standard inhibiting offshore tax avoidance and evasion; it does however mean that there is a major increase in reporting requirements for mangers.

We can help assist in making this process hassle-free and help funds prepare to comply with CRS obligations.

Services include:

In accordance with account opening procedures, record one or multiple tax residencies where applicable
Classifying investors tax status based on documentation provided
Contacting investors to obtain additional tax documentation where required
Performing a full review of investors on December 31st each year to identify any change of circumstances
Reporting on accounts that are classified as ‘undocumented accounts’ post the due diligence reviews
Reporting on all accounts deemed to be held by a CRS reportable account to the relevant local tax authority within the specified reporting deadlines using the CRS XML Reporting Schema
Acting as the principal point of contact through one of our employees
Keeping a record of the documents as per the regulatory provisions and provide a report to the board of the company

As part of the reporting obligations under AIFMD, all European registered alternative asset managers marketing into the EU or EEA are now required to report to their particular jurisdiction under AIFMD.

Non-EU alternative fund asset managers are also required to file in all jurisdictions into which they market.

There are two Annex IV report categories:

AIFM report: A consolidated view of assets managed
AIF report: Required for each fund detailing assets held, exposures, investor profiles etc.

Our process is an easy to manage end-to-end filing process affording AIFMs one of our local dedicated account managers, alongside the backing of a global firm, experienced with multiple jurisdictional and regulatory requirements.

Our Annex IV Reporting service uses market leading technology to ensure accuracy, consistency, timeliness, and control.

Services include:

Conducting an initial scoping exercise to determine the reporting frequency and initial reference data for the AIFM and AIF
Agreeing with the AIFM the process to obtain and confirm reference / static data for subsequent reports
Agree how and what we will collect with regards to information required to complete the Annex IV reporting that we do not already have in our possession
Delivering in excel or HTML the completed ESMA Annex IV template with corresponding support documentation for the AIFMs approval
After the AIFM approves the ESMA template prepared by us, convert the template to a submission ready XML format
Delivering the submission ready XML file to the AIFM

Form PF is a US Securities and Exchange Commission (“SEC”) regulatory filing requirement and affects SEC registered managers of private equity funds, real estate funds, hedge funds, and liquidity funds with at least US $150 million in private funds assets.

We can help assist in making this process hassle free and help you prepare to comply with this obligation.

Services include:

Conducting an initial scoping exercise to determine the reporting frequency and initial reference data required
Agreeing on the process with you to obtain and confirm reference/ static data for subsequent reports
Agreeing how and what we will collect with regards to information required to complete the Form PF reporting that we do not already have in our possession
Providing access to our cloud based portal where you can review and sign-off files, drill down into underlying details and run period to period comparison reports
Coordinating the data, run jurisdiction specific validations, and manage the end-to-end process
Providing you with a submission ready file or discuss the provision of submission services