The AIFMD Q&A document was updated by ESMA on 4 December 2019 to highlight how AIFMs should report results of liquidity stress tests for closed-ended unleveraged AIFs that they manage.
ESMA has confirmed that Article 16(1) exempts closed-ended unleveraged AIFs from implementing liquidity risk management systems and from “conducting stress tests, under normal and exceptional liquidity conditions, which enable AIFMs to assess the liquidity risk of the AIFs and monitor the liquidity risk of the AIFs accordingly” (liquidity stress tests). However, AIFMs need to report results of liquidity stress tests for all their AIFs as part of their reporting to competent authorities as particularly required in accordance with Article 24(2) of the AIFMD, further specified by Article 110(2)(f) of Commission Delegated Regulation (EU) No 231/2013, and integrated in field 280 of the AIFMD reporting template. For closed-ended unleveraged AIFs, given the mandatory character of the field, AIFMs should indicate the question is Not Applicable and at least report in this field the fact that the relevant fund is a closed-ended unleveraged AIF. However, where an AIFM decides to conduct liquidity stress tests for unleveraged closed ended AIFs, it should report the results of the liquidity stress tests in the same field.