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Loans originated by AIFs: the AMF amends its guidelines on reporting requirements
26 October 2023

Loans originated by AIFs: the AMF amends its guidelines on reporting requirements

Following the approval of amendments to its General Regulation, the Autorité des Marchés Financiers (AMF) is amending its instruction DOC-2016-02 concerning the AMF's disclosures on loans originated by alternative investment funds (AIF).


To recall, AIFs that are compatible with Regulation (EU) 2015/760 of the European Parliament and of the Council of 29 April 2015 on European long-term investment funds (ELTIF Regulation) can be ELTIF-authorised and originate loans under the conditions of this Regulation. With regard to non-ELTIF authorised AIFs, only AIFs specifically authorised by national legislation may originate loans (professional specialised funds (FPS), professional private equity funds (FPCI), securitisation vehicles (SV) and specialised financing vehicles (SFV)).

Portfolio management companies authorised in France which manage FPS, FPCIs, SVs or SFVs, whether or not they are ELTIF authorised, and which originate loans, must provide the AMF with quarterly information on loans originated which are not yet due. Foreign investment management companies managing such non-ELTIF authorised French AIFs and originating loans are subject to the same obligation.

Extension of the scope of reporting obligations to certain managers of French lending AIFs

In order to improve data-driven supervision, and following the amendments made to its General Regulation by the Decree of 21 July 2023, the AMF is amending its Instruction DOC-2016-02 and is extending these reporting obligations to the following actors:

  • portfolio management companies managing ELTIF-authorised “Other AIFs” and originating loans, and
  • foreign investment management companies that manage loan-granting ELTIF-authorised FPS, FPCIs, SVs or SFVs, or that manage loan-granting ELTIF-authorised “Other AIFs”.

Integration of information in the ROSA Extranet

Portfolio management companies authorised in France and foreign management companies managing French AIFs that originate loans must now enter new, more detailed information on loans originated directly on the ROSA extranet instead of via the GECO database.

The deadline for submitting this information remains the same, i.e., within two months of the end of each quarter of the calendar year.

The new format for reporting to the AMF will apply from November for lending activities relating to the third quarter of 2023. Reporting procedures will be specified on the ROSA Extranet.