On 1 June 2017, Bank of Italy published a consultation document on certain amendments to the reporting rules of Bank of Italy and CONSOB for asset management companies (“AMCs”) and collective investment undertakings (“CIUs”).

Such changes aim at (a) streamlining the flow of information to the authorities, while reducing duties for firms; and (b) adapting the national legal framework to the most recent updates at EU level.

In particular, the proposed amendments refer to:

  • Bank of Italy’s Circular n. 189 – Handbook for statistical and supervisory reports of collective investment undertakings:
    1. Introduction of new information details – categorization of clients as retail or professional, ISIN code of purchased and sold securities, etc. – to be transmitted directly to Bank of Italy (and not anymore, on a separate basis, to CONSOB);
    2. Removal of certain items on the funds’ operations (including portfolio composition and some data on fees paid by funds and unitholders);
    3. Addition of new sub-items on credit quality, country of residence and economic sector of debtors;
    4. Introduction of reporting obligations for investment companies with fixed capital (SICAFs);
    5. Set up of an information regime for European Venture Capital Funds (EUVECA) and European Social Entrepreneurship Funds (EUSEF), similar to the one in place for closed-end funds.
  • CONSOB’s Resolution n. 17297 of 28 April 2010:
    1. Abolition of duplicated reporting obligations for data already transmitted by AMCs and CIUs to Bank of Italy;
    2. Elimination of the reporting obligation for information that can be obtained by CONSOB using databases already at its disposal;
    3. Removal of the reporting obligation for private equity UCITS;
    4. Introduction of certain amendments on the reporting of sale of own and third parties’ CIUs, in order to obtain better compliance with the supervisory needs;
    5. Extension of the reporting obligations of Italian law UCITS managed by Italian managers to EU management companies and to managers of Alternative Investment Funds (AIF);
    6. Certain amendments to the reporting of real estate funds.

Following the consultation period – and subject to final amendments and approval – the revised Circular and Resolution will enter into force on 31 December 2017.

Responses to the consultation document may be submitted not later than 31 July 2017.

We would be happy to offer you any required assistance in submitting your response or any further clarification on the above.