Founder & CEO
The key to successful regulatory reporting is preparation. Minimisation of change during the critical filing period will de-risk the regulatory reporting process. Eleventh-hour changes and manual processes introduce regulatory risk. Every firm can reduce this risk by undertaking these 5 key activities in the run up to year-end. De-risking regulatory filings is on the agenda of every reporting firm.
1. Confirm the funds in-scope for reporting and the jurisdictions for reporting
If the firm has registered with new international jurisdictions during the year, there may or may not be a requirement to file. There can be a quarterly lag between registration and reporting, and this will vary on a jurisdictional basis. We suggest logging in to the regulator portals and checking the funds that are registered. If in doubt, contact the regulator to verify the funds registered for reporting. For funds filing FormPF, now is the time to ensure all funds are added to FormADV. We recommend that ADV is updated on an ongoing basis, for launches throughout the year.
2. Map out the data requirements and delivery timelines across all data sources
The source data for regulatory filings can come from multiple sources, including fund administrators, asset servicers and in-house platforms. Every firm should have a documented master data flow schematic. This reference diagram should include all data sources, flow of data, and destination requirements.
For each third party data source, set clear delivery timelines with the data processor tasked with sharing required data for reporting, including NAV, position and transaction data. NAVs can be delayed for year end filings, due to pricing delays for illiquid instruments such real estate. Factor this into the data sourcing and collection timelines. Automated interfaces should be established where possible, and priority should be given to the large volume data sets, such as transactional data.
3. Refresh regulatory filing knowledge within the Compliance team
For annual filers, in-house knowledge for the regulatory reports can diminish over time, or there may have been team changes, in year. Now is the time to Schedule some refresher training sessions with the team. This training should include familiarisation with the new regulator portals, submission methods along with a review of the form itself and the underlying data. AQMetrics regularly provides this training to client firms, incorporating best practices on how to resolve real-world data and reporting challenges.
4. Test access to regulator portals, set up new users
Ensure user access levels to regulators’ portals are still active and passwords are checked.Often this is an 11th hour task by firms but this can be easily taken off the critical path. The level of administrative support available within the regulator for user access can vary across jurisdictions, so early is always better. For CSSF reporting, all reporting firms and funds must be registered with one of the CSSF approved submitting entities. AQMetrics connects directly with the CSSF submitting entities, and can perform this registration on behalf of reporting firms.
5. Run a quality audit on static report data
Finally, now is the time to run some quality checks on the static or slowly changing data in the reports. This static data audit can help detect unnoticed reporting errors in historical filings. At AQMetrics, we create partial regulatory filings 6 weeks in advance of the deadline, and work with client firms to review and sign off the static non-changing data points. Typical changes include changes in the manager set-up, strategy, fund names and contact details.
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