Last summer, the U.K. Financial Conduct Authority (FCA) set out proposals for a significant change to the Annex IV reporting requirements under the Alternative Investment Fund Managers Directive. The FCA proposed amendments to its handbook that would expand the Annex IV reporting obligations of certain alternative investment fund managers (AIFMs) located in the U.K., as well as outside of the European Economic Area (EEA), that market non-EEA alternative investment funds (AIFs) to U.K. investors via the country’s national private placement regime. See “U.S. Managers Marketing to U.K. Investors Could Face Ballooning Reporting Burdens Under Proposed Rule” (Jul. 28, 2016). The new rules would specifically require those AIFMs to file Annex IV reports at the master AIF level; whereas, historically, the FCA had limited reporting by those AIFMs to the feeder AIF level. See “U.K. FCA Guidance Confirms Simplified Transparency Reporting for Certain Private Placements of Master-Feeder Funds” (Nov. 20, 2014). In a guest article, Devarshi Saksena and Lucian Firth, partner and managing associate, respectively, at Simmons & Simmons, consider the implications of this amendment, including what has changed and whom it affects, and provide practical guidance on how firms can comply with the new reporting requirements. For additional insight from counsel at Simmons & Simmons, see “Seward & Kissel Private Funds Forum Offers Practical Steps for Fund Managers to Address HSR Act Enforcement, Tax Reforms, Brexit Uncertainty, MiFID II, Cybersecurity and Side Letters” (Oct. 20, 2016).