On January 9th 2015, the European Securities and Markets Authority ("ESMA") issued an updated version of its Q&A on the application of AIFMD (the "Q&A").
New questions have been added to Section III of the document relating to "Reporting to national competent authorities under Articles 3, 24 and 42 (of AIFMD)" to clarify the data to be reported under the consolidated reporting template.
In relation to subscription and redemption orders the Q&A clarifies that AIFMs should report their value and not their number. Therefore information should be reported for the month of the cash-flows and not the month when the subscription and redemption orders happen unless they happen in the same month.
In relation to the reporting on the change in NAV per month (questions 243 to 254 of the consolidated reporting template) and on the percentage of gross and net investment returns per month (questions 219 to 242 of the consolidated reporting template) the Q&A clarifies that AIFMs should report the information for each month of the reporting period. If no official NAV is available for the calculation, AIFMs should use estimates of the NAV. In some cases (e.g. for AIFs investing in illiquid assets), the best estimate may be the previous NAV.
Finally the Q&A clarifies that where an AIFM manages both funds and funds of funds, aggregated information at the level of the AIFM and information on the AIFs that are funds of funds should be reported no later than 45 days after the end of the reporting period. Information on AIFs that are not fund of funds should be reported one month after the end of the reporting period.