SBAI Response to ESMA on AIFMD Reporting Guidelines (Articles 3 and 24) (ESMA/2013/592)

SBAI responds to ESMA’s AIFMD Consultation on reporting obligations focusing on the need for greater transparency and consistency of risk reporting.

We have always been an advocate for greater transparency and consistency of risk reporting as demonstrated in the Alternative Investment Standards. Standardisation of risk disclosure benefits all involved and is a positive development for the industry.

Regulatory efforts to standardise risk reporting may serve as a catalyst for more consistent disclosure to investors facilitating better investment decisions, however, it is important that the format of data collection is well structured and coherent. Work on standardisation of risk reporting has already taken place through regulators (such as the US SEC Form PF) and industry driven initiatives such as the Open Protocol Risk Reporting framework.

We encourage ESMA to consider the SEC’s Form PF and the findings of the Open Protocol working group to ensure consistency, improve usability, and minimise costs for industry participants.

https://www.esma.europa.eu/sites/default/files/library/2015/11/2013-592_consultation_paper_on_esma_guidelines_on_aifmd_reporting_for_publication.pdf