Regulatory Reporting Under AIFMD – An Update And Comparison To SEC's Form PF

The Alternative Investment Fund Managers Directive (the "AIFMD") introduces new regulatory reporting requirements for alternative investment fund managers ("AIFMs") established in the European Economic Area ("EEA") and non-EEA AIFMs that market their fund in an EEA state. These requirements are broadly similar those already imposed in the U.S. on registered investment advisers that manager private funds, pursuant to the Form PF reporting regime, although there are important differences between AIFMD reporting and Form PF.

In particular, AIFMs that are established in the EEA and non-EEA AIFMs that market into an EEA state must satisfy the AIFMD's regulatory reporting obligations. For a non-EEA AIFM, registering under a private placement regime in an EEA state triggers these requirements. AIFMs that became authorized towards the end of the transitional period (which ended on 22 July 2014), and non-EEA AIFMs that marketed in the EEA after the end of transitional period,