One size fits all? Implementing AIFMD in the EU and around the world

onesize
Does one size really fit all? Lately, in the world of alternative investments, it has to. The Alternative Investment Fund Management Directive (AIFMD) has been signed into law in all EU member states over the past few years, affecting change in the asset and wealth management market and its firms through enforcement of a universal regulatory framework. While it is a directive enforced by the European Commission, AIFMD’s sphere of influence extends to all alternative investment funds (AIFs) that market to or involve European investors, regardless of where they are based.

These regulations are meant to do many things: decrease market instability, enhance supervisory practices, and foster cross-border competition. Concrete changes we will see include new structures for future AIFs and a passport regime that will regulate and encourage cross-border interaction. All firms involved have been preparing for years now, adjusting their legal structures, processes, and budgets.

So why was July 22nd important? It was the deadline by which all preexisting AIFs should have fully complied with the directive. However, the process doesn’t end there. Key dates for now and the future include:

  • July 22, 2014: Managers operating pre-July 2013 must be authorized and comply in full
  • July 2013-2014: Passports are available to EU managed EU funds and non-EU managed EU funds
  • July 2015: Passports become available to EU managed non-EU funds and non-EU managed non-EU funds
  • January 22, 2019: European Commission may end domestic private placement regimes

AIFs are changing in many ways, but reporting will likely have the biggest impact because of the increased amount of time, effort, and money that it necessitates. The Annex IV Report is the main reporting component of AIFMD, and requires quarterly accounting of different aspects of an AIF so as to offer a detailed picture of it for review.

By applying a single framework to all AIFs and all EU member states, it may appear as though the European Commission is expecting one size to fit a varying population of firms. There is wiggle room—the directive has different nuances country by country—but the overarching structure remains universal and mandatory.

Regardless of the generalities and intricacies that AIFMD entails, one thing is clear: with such a diverse collection of governments, getting one size to fit all is surely no easy feat.

Martin Engdal is Market Strategist and Director of Solution Marketing at Advent EMEA. In this role, he has responsibility for strategic positioning of Advent’s solutions in EMEA and for driving Business Development efforts in Europe, Middle East and Africa.

Martin Sreba has been with Advent since 2000, holding a variety of senior roles in product services and sales. Currently he is a Principal in the Global Accounts Sales Organization.

Posted in Advent Software, Asset Managers, Compliance, Global, Hedge Funds, Wealth Management

Making Moments of Magic

magic

Picture a great service interaction you’ve had versus a poor one. One probably made you want to bang your head on your desk, while the other answered all your questions. Customer service guru, Shep Hyken calls these moments of magic and moments of misery. We want every interaction you have with Advent and our community to be MAGIC!

Advent has 250 support team members, more than 4,300 client firms in over 50 countries; and we are here to help you solve the hard problems.

How will Advent make sure we have great interactions with your team? Check out these two new videos below.

I hope you find them impactful and informative. And as always, I’d love to hear your thoughts!

Cheers!

Casey

Casey is VP, Global Client Services at Advent. With a background in Investments, Service, and Tech, Casey seeks to share thoughts with Clients and other Professionals. Follow Casey on Twitter.

Posted in Advent Direct Community, Advent Software

Facing Cost Basis Legislation Challenges in 2014. Is this you?

confused computer dudeImagine this.

You’re a 100% fixed income manager who is anxious about the pending changes to cost basis regulation – specifically the treatment of debt instruments.  Your firm has historically provided amortization/accretion information and realized gain data to clients and their accountants. But now, as a result of the cost basis legislation, this responsibility has fallen on the custodian and burdened your firm to not only conform to the custodian’s data but also to ensure it’s correct.

True story. I spoke to a client in this scenario in March 2013. Needless to say, this has been a big change for her team.

I spend a lot of time chatting with Advent clients across the globe to understand how specific regulations are affecting their firms. My goal is to make sure we deliver features that help firms manage regulatory changes and address the US cost basis legislation concerns I hear so much about.

I won’t argue that custodians and brokers haven’t felt the biggest impact from cost basis legislation, yet the challenges posed to the investment management community are a shared problem…with many of our clients caught in the middle.  As it turns out, the 2014 phase of legislation might be as impactful to them as the earlier phases, in that their workflows, operations, and client servicing could be affected.

To ease the burden for our clients, we began working on new Advent Portfolio Exchange (APX) features for the 2014 phase of legislation well ahead of the effective date:

  • October 2013: This release of APX made changes to the transaction codes, which made it easier for our clients to adjust the cost basis of existing positions.
  • April 2014:
    • We expanded the transaction code feature in APX to better connect it with the data that many custodians are already providing through Advent Custodial Data. Enhancements have also been made to the way clients reconcile the adjusted/amortized cost basis of fixed income positions with their custodian’s calculations (expanding on a long time capability to reconcile the original cost basis), but can also easily update it in APX based on the data provided from the custodian.

The feedback we’ve received on these features has been overwhelmingly positive. In fact, the scenario mentioned above ended with me sharing the cost basis changes in APX 14.1 and the fixed income manager saying, “We want the upgrade.”

That’s the feedback I’m always striving for – it’s how I know we’re connecting with our clients in a meaningful way.

If you’re an Advent client and have an idea you think might make dealing with cost basis regulations easier, let us know about it in the Advent Direct Community on one of our discussion boards or on our product idea forums.  Or, if you’re an Advent client and want to know more about the new reconciliation options in APX 14.1, take a look at a few of these training videos, and stay tuned for an upcoming post. If you aren’t an Advent client or simply want to talk about the impacts of the cost basis legislation at your firm, shoot me an email at Matt.Ahlstrand@Advent.com.

Matt Ahlstrand joined Advent in 2002 as part of the services organization.  He is currently a Sr. Director of Solutions Consulting where he specializes in helping investment management firms better understand, evaluate, and leverage technology.  Additionally, he’s responsible for shaping the roadmap for Advent’s APX product.

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Posted in Asset Managers, Compliance, Trends

What Happens in Vegas…

VEGAAS

T minus 40 days. I’m looking forward to seeing familiar faces and meeting new attendees at AdventConnect Las Vegas in September.

Last year we revealed Advent Direct our new cloud-based platform that enables rapid development and delivery of mobile solutions essential to your business. It can help our clients leverage new capabilities in the Cloud without having to replace their underlying accounting systems. This year we are set to show you how far it has come. We have a killer lineup of sessions designed to give you a firsthand look into our solutions, share industry trends around the Cloud and other market drivers, and simply help your firm grow assets, collaborate more effectively, and improve your operations. Here are a couple of my favorites:

  • Advent Direct Investor Management: As the first solution available on the Advent Direct platform, Advent Direct Investor Management enables client facing-teams to more effectively manage and grow relationships.  Register to learn more about how it can help drive collaboration and productivity at your firm, and hear directly from users about their experience.
  • Cloud – A Clearer View: Hear the latest trends in Cloud computing and how firms are using the cloud to take their business to the next level.

If you’ve registered to attend AdventConnect Las Vegas, you can see the entire session lineup here. Hope to see you at the Wynn September 8-10. Because let’s face it, what happens in Vegas … could change your business.

Thomas Zdon joined Advent in 1997 and is now the Vice President of Global Solutions Management. 

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Posted in Advent Direct Community, AdventConnect, Trends

A Beginner’s Guide to FATCA

REGULATE!Every year, the month of July dependably brings about its annual mile markers: the beginning of a new quarter, the arrival of summer weather, and the second half of the year. This year, it also brought a not-so-little something extra for everyone in the financial sector.

The Foreign Account Tax Compliance Act, called ‘FATCA,’ is officially in effect as of July 1st, 2014. While it wasn’t exactly judgment day or the apocalypse, it begot something that financial managers may consider equally damning: government regulation. Here’s what you should know.

FATCA requires non-US financial institutions—known as Foreign Financial Institutions (FFIs)—to report on deposits or assets owned by US citizens or residents. It primarily helps curtail tax evasion with foreign accounts, but it will affect all people with any kind of foreign financial involvement. This includes US taxpayers with money in foreign accounts and any non-US banks, asset managers, hedge funds, private equity funds, custodians, or brokers that are catering to US clients.

July 1st marked the official FATCA start date, but the law has been in effect since March of 2010. A recent update by the IRS extended some of the law’s provisions until 2016, giving firms a two-year period to ease into some of the requirements. Important dates to keep in mind:

  • July 1st, 2014: FATCA withholding  on FDAP (Fixed, Determinable, Annual, Periodical) income payments to non-participating FFIs, non-compliant NFFEs and recalcitrant account holders begins
  • July 1st, 2014: New account onboarding  process goes into effect
  • July 1st, 2015: Due diligence on pre-existing individual investors
  • July 1st, 2016: Due diligence on pre-existing entity investors

It sounds overwhelming, but the regulators did give firms some breathing room. The two-year phasing-in of key requirements is a way for regulators to jump-start the processes that FATCA entails and bring the law to full force by 2016.

The greatest burden on FFIs will be reporting, due diligence, and identification of US investors. Advent’s Geneva World Investor will help make these new operational requirements a lot more streamlined and easier to implement. This integrated fund and investor accounting platform will provide comprehensive views of the firm’s investor base, allowing for easier identification, classification, tracking, and reporting on the FATCA status of individual investors.

While there has been a great amount of emphasis placed on the July 1st deadline, some firms began their due diligence on FATCA as early as 2010, the year this regulation became law. Advent can help by shouldering some of this compliance burden as firms continue to navigate through a complex terrain of many new regulations.

Martin Sreba has been with Advent since 2000, holding a variety of senior roles in product services and sales. Currently he is a Principal in the Global Accounts Sales Organization.
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Posted in Advent Software, Compliance, Global

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