The Cyprus Securities and Exchange Commission (CySEC) recently issued a crucial circular emphasizing the submission of quarterly statistics for the fourth quarter of 2024. This new directive targets a diverse array of entities, which include Alternative Investment Fund Managers (AIFMs), UCITS Management Companies, and internally managed funds. This article delves into the requirements set by CySEC's latest circular, focusing on important compliance aspects fund managers need to know.
What Are the New Reporting Requirements?
All entities outlined in the CySEC circular are required to use the updated version of the reporting form, known as QST-MC Version 22. This submission must be made to the Transaction Reporting System (TRS) by January 31, 2025. The updated form incorporates a new column demanding the ISIN code for each sub-fund. In cases where this code is unavailable, entities are instructed to insert "N/A." Additionally, data must be reported using the euro as the unit and must align with all validation checks.
What are the Compliance Requirements for Fund Managers in 2025?
CySEC's circular clarifies that all entities authorized or appointed as External Managers by December 31, 2024, are obliged to comply with this directive, even if they have not begun utilizing their authorisation. This ensures that the reporting covers a comprehensive spectrum of funds and sub-funds, with each umbrella fund needing to account for its sub-funds individually when completing relevant sections.
How to Ensure Successful Submission?
For a submission to be successfully acknowledged by CySEC, entities must receive a feedback file which shows "no error." Should any errors emerge, they are expected to rectify and resubmit the form promptly. Compliance is non-negotiable, with the potential of administrative penalties looming for missed deadlines or erroneous submissions. It's worth noting that CySEC underscored the importance of timely submissions by dispensing with the practice of issuing late reminders.
What Are the Penalties for Non-compliance?
In keeping with section 37(5) of the CySEC Law, failing to comply with the aforementioned requirements may result in administrative penalties. CySEC's decision to eliminate late submission reminders signifies a more stringent approach to regulatory adherence. Hence, regulated entities must proactively manage their reporting schedules to avert any compliance missteps.
How Can Tsitsios & Associates LLC Help You Navigate CySEC Requirements?
At Tsitsios & Associates LLC, our specialised corporate and business legal services offer robust support for compliance with CySEC directives. Our expert team is equipped to assist firms of any size in navigating these regulatory complexities, ensuring your operations align with CySEC standards. Should you require further assistance, feel free to reach out to us at info@klztlaw.com.
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