“AIFMs should report the value of subscription and redemption orders and not the number of subscription and redemption orders.”
In older ESMA documentation it is suggested that subscriptions and redemptions should be reported in number of subscriptions and redemptions. Later on it was made clear (see ESMA Q&A Question 50) that subscriptions and redemptions must be reported in Base Currency (as entered in AIF Question 49).
How should AIFMs report information on subscriptions and redemptions over the reporting period (questions 255 to 278 of the consolidated reporting template)?
AIFMs should report the value of subscription and redemption orders and not the number of subscription and redemption orders. Information should be reported for the month of the cash-flows and not for the month of the subscription and redemption orders unless it is the same month.
For example, an AIFM is subject to quarterly reporting obligations and investors can subscribe/redeem 4 times per year on the NAVs of 31/03, 30/06, 30/09 and 31/12 of each year. The AIFM receives for January 100 redemption orders, for February 200 redemption orders and for March 50 redemption orders (350 redemption orders in total over the reporting period Q1). Redemption orders are executed in April on the NAV calculated on 31 March. The NAV is €100 per share. Therefore, the AIFM will report redemption orders for a total value of €35,000 (350*100) in April (reporting for Q2).
Should AIFMs consider commitments or actual capital drawdowns when they report information on subscriptions over the reporting period for AIFs pursuing private equity strategies (questions 255 to 266 of the consolidated reporting template)?
AIFMs should consider actual capital drawdowns and not commitments when they report information on subscriptions for AIFs pursuing private equity strategies.
Should AIFMs consider distribution of dividends to investors as redemptions for the purpose of questions 267 to 278 of the consolidated reporting template?
No.
Is information on gross and net investment returns, change in NAV, subscriptions and redemptions mandatory or optional?
This information is mandatory for Article 24(2) AIF reporting contents but, to enable the necessary functional flexibility, it is classified as optional from a technical standpoint. This information is optional from a technical standpoint because AIFMs only have to report this information for the months corresponding to the reporting period for which they report. For example, an AIFM that reports on quarterly basis will report in Q2 only information for April, May and June and not for January, February and March. Information on January, February and March would have been part of the report for Q1.
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