On December 2, the European Securities and Markets Authority published an updated Questions and Answers (Updated Q&A) on the Alternative Investment Fund Managers Directive (AIFMD). The Updated Q&A focuses on Section III regarding the reporting of information to national competent authorities.

Among other issues, the Updated Q&A notes that all leveraged loans, whether syndicated or otherwise, should be disclosed as leveraged loans. Additionally, alternative investment fund managers (AIFMs) are required to report cash from repurchase agreements as cash borrowings. Further, AIFMs should exclude the investments of alternative investment funds (AIFs) in other AIFs they manage for the purpose of calculating the total value of assets under management.

A copy of the Updated Q&A can be found here.