Documentation — AIFMD Gap Analysis
Although non‐EEA-based fund advisers will not be required to seek authorisation until a future date to be determined, these firms will still need to comply with some of the provisions of AIFMD if they wish to market into the EEA.
ACA can undertake an AIFMD gap analysis of documents and reporting controls of a non-EEA-based fund manager to compare current disclosures with those required under the Directive’s pre-investment and periodic disclosure requirements, as well as annual fund reporting requirements.
Our initial work on the gap analysis will focus on the following documents:
- Current fund offering documents
- Due diligence questionnaires
- Marketing materials, across all media
- Monthly portfolio summaries and other investor communications
- The fund’s annual financial statements and supporting notes
Once we have completed our review, we will work with you to address any gaps that have been identified, including drafting new text for non‐legal documentation as well as introducing practical AIFMD‐compliant procedures and controls to meet the requirements.