Regulatory reporting

Regulatory reporting is a growing burden and regulators continue to take disciplinary action against firms for missing filings or reporting incorrect data. We have reporting specialists in Singapore, Hong Kong, the UK, and US who can help with MAS and SFC reporting, and international requirements from Annex IV, to Form PF, Form 13F and Form CPO-PQR. Our team can help with all elements of completing your returns, from breaking down methodologies and calculating portfolio responses to making the final submission directly to the relevant regulator on your behalf.

Regulatory reporting in Singapore

CMSL holders are required to send detailed quarterly reports to the MAS within 14 calendar days of quarter end.  We can either prepare these reports for you, using your management accounts as a starting point, or we can review versions that you have drafted.  Either way, you will benefit from our deep expertise in interpreting the MAS’ complex requirements on risk-based capital, and in ensuring that the reports validate and as such can be submitted via MASNET.

We are also on hand to answer any other capital questions.  Recently we helped a client to determine whether a change in its capital structure would impact its base capital and financial resources.  Another client was changing its fee structure and needed to know whether this would trigger punitive deductions from financial resources.

Regulatory reporting in Hong Kong

SFC licensees are required to submit financial resources returns (FRR) to the SFC monthly / semi-annually, depending on the types of license they are holding. The FRR is required to be submitted within 21 days after the period end.  We can either prepare these returns for you, using your management accounts as a starting point, or we can review versions that you have drafted. We can help interpreting the SFC’s requirements on liquid capital computations, and in ensuring that the FRR validates and can be submitted via eFRR portal.  We can also help preparing notification to the SFC if there are any notifiable events, e.g. a significant drop in liquid capital level.

Regulatory reporting in the US

Form PF

The SEC has expressed renewed interest in ensuring firms are compliant with their regulatory reporting obligations. Form PF was introduced in 2012, and requires private funds to report on their regulatory assets under management (RAUM). Firms’ reporting frequency will be based on the fund structure and RAUM. Private funds are required to submit returns either quarterly or annually. We will work with you to ensure your asset classification, RAUM and risk exposure calculations are in line with the high standards expected by the regulator. We can help you with completing your Form PF returns all the way through from the initial discussions regarding methodologies to the final submission in FINRA. We have the technology to do this on your behalf.

Form 13F

Form 13F is a quarterly report, required by the SEC, for institutional investment managers that hold over $100 million in market value of specified securities. The list of specified securities can be found in the SEC’s official list. Form 13F is intended to increase the public availability of information on the securities holdings of institutional investors. The report is submitted through the SEC’s EDGAR system, and the filings are made available to the general public. We can help you break down the methodologies behind the procedures, perform the relevant calculations and file the report to the SEC on your behalf.

Form CPO-PQR

The Commodity Futures Trading Commission (CFTC) requires Commodity Pool Operators (CPOs) to file Form CPO-PQR. Generally, all CPOs that operate at least one pool during a reporting period must complete and file a Form CPO-PQR for that reporting period. A CPO may report either quarterly or annually, depending on the size of its assets under management. CPO-PQR looks for firms to report on use of leverage, AUM, counterparty credit risk exposure and turnover among many other data sections. We can help you with the preparation and submission of the CPO-PQR filing from start to finish. We also have the technology to submit the data to the CFTC/NFA on your behalf.

Regulatory reporting in the UK and Europe

Annex IV

Meeting the challenging reporting requirements of AIFMD Annex IV means significant investment in software and skills. Determining how and what you need to report is complex and depends on your structure and AUM. Most AIFMs who are managing or marketing AIFs into the European Union or EEA will have to complete Annex IV reports. The reports will have to be submitted to the relevant National Competent Authority (NCA), which in the UK is the FCA. A non-EEA AIFM will have to file a report to the NCA of each member state in which they market an AIF. Firms are required to make returns either quarterly, bi-annually or annually. We can assist you with the completion of these returns, especially as they can require complex risk calculations and all returns need to be submitted to the FCA in a special XML formatted file. We have acquired the necessary technology in order to enable us to file the reports on behalf of the AIFM in multiple jurisdictions, including Luxembourg.

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