MFSA Extends Regulatory Reporting Deadlines for Investment Firms, Funds and Managers

In light of the current pandemic in which we find ourselves, the MFSA has announced that it will be extending the deadlines for submission of regulatory reporting for investment firms, investment funds and fund managers which fall due by March or April 2020. However, with regard to those submissions which fall due by May or June 2020, the MFSA is reluctant to grant extensions for the time-being.

1. Investment Firms

Category 1-4 (excluding credit institutions) – Annual Report, Audited Financial Statements, COREP Return, and Management Letter, Circularisation Exercise Report

Deadlines for submissions due by March or April 2020 shall be extended by two months from the reporting date. This extension is not automatically applicable and will only be granted, on a case by case basis, following an official request to the MFSA.

Recovery Plans and High-Income Earners under the CRD package

For the time-being deadlines for submissions due by April and June 2020 respectively will not be extended, however the MFSA may reconsider based on its ongoing assessment of the situation.

Recovery Plan Confirmation for Local Firms

For the time-being deadlines for submissions due by April 2020 will not be extended, however the MFSA may reconsider based on its ongoing assessment of the situation.

System Certification Confirmation

Deadlines for submissions due by June 2020 will not be extended as the MFSA deems it premature to do so at this stage.

Conduct-related data return for Investment Firms

For the time-being deadlines for submissions due by May 2020 will not be extended, however the MFSA may reconsider based on its ongoing assessment of the situation. This information is needed in order to report to ESMA regarding complaints and retail investor trends.

Survey on cross-border activities by Investment Firms

For the time-being deadlines for submissions due by (25) March 2020 will not be extended, however the MFSA, in close coordination with ESMA, may reconsider based on its ongoing assessment of the situation. This survey forms part of ESMA’s thematic review as part of its supervisory convergence initiatives.

2. Investment Funds and Fund Managers

UCITS and UCITS ManCos, AIFs and AIFMs – Annual Report, Audited Financial Statements, Interim/Annual Financial Return, Management Letter and Confirmations

Deadlines for submissions due by March or April 2020 shall be extended by two months from the reporting date. This extension is not automatically applicable and will only be granted, on a case by case basis, following an official request to the MFSA.

Professional Investor Funds – Annual Report, Audited Financial Statements, Management Letter, Custodian Report, Auditor’s Confirmation, SRO Declaration

Deadlines for submissions due by March or April 2020 shall be extended by two months for all entities.

Recognised Persons (RFAs, RICCs, PCIS), De Minimis AIFMs – Annual Report, Audited Financial Statements, Auditor’s Report, Audited Financial Return, Management Letter, Board Confirmation, Auditor’s Confirmation

Deadlines for submissions due by March or April 2020 shall be extended by two months for all entities.

De Minimis AIFMs, AIFMs, UCITS ManCo – Annex V Return, Self-Assessment Closet Indexing

For the time-being deadlines for submissions due by March or April 2020 will not be extended, however the MFSA may reconsider based on its on-going assessment of the situation.

Survey on UCITS liquidity risk management

For the time-being deadlines for submissions due by (6) April 2020 will not be extended, however the MFSA, in close coordination with ESMA, may reconsider based on its on-going assessment of the situation. This survey forms part of ESMA’s Common Supervisory Action on Liquidity Risk Management.