The Luxembourg financial services regulator, the CSSF, and its Belgian counterpart, the FSMA, will shortly require non-EU alternative investment fund managers, who distribute non-EU feeder AIFs under the national private placement regimes, to include master funds in their Annex IV reports.

This obligation is in effect as of the 'Q1 2015' report that the firms have to submit by 30 April 2015. The Alternative Investment Fund Managers' Directive defines a 'feeder' as a fund that invests at least 85% of its assets in a master. The directive says that documents pertaining to any feeder AIF should include information about the master as well. Now this information requirement is carried through into the regulatory reporting and extended to funds distributed under the private placement regimes in the two countries.

This is the latest example of the small, but nonetheless significant, permutations in the practical implementation of AIFMD at the local market level arising as a consequence of the different fund distribution rules that exist across Europe. The European Union's review of national private placement regimes later this year may propose further standardisation of the rules for distributing funds without a so-called 'passport.'