CySEC Circular C627: Submission of Form QST-MC for Q1 2024

TO : Regulated Entities: i. Alternative Investment Fund Managers (‘AIFMs’) ii. Internally Managed Alternative Investment Funds iii. UCITS Management Companies iv. Internally Managed UCITS v. Internally Managed Alternative Investment Funds with Limited Number of Persons (‘AIFLNP’) vi. Companies with sole purpose the management of AIFLNPs vii. Small AIFMs FROM : Cyprus Securities and Exchange Commission DATE : April 03, 2024 CIRCULAR No : C627 FILE No : 01.13.001.002.002 SUBJECT : Management Companies and Self-Managed Funds Quarterly Statistics – Submission for Q1 2024 (31/03/2024) The present Circular is issued pursuant to section 25(1)(c)(ii) & (iii) of the Cyprus Securities and Exchange Commission Law (‘the CySEC Law’). The Cyprus Securities and Exchange Commission ('the CySEC') wishes to inform Regulated Entities about the following:

1. Information Requested by CySEC 1.1 The latest version of the form, QST-MC Version 21 (‘the Form’), found in the Appendix, must be completed and submitted to CySEC by all Regulated Entities that were authorised or appointed to act as External Managers (in case no authorisation is required by the relevant legislation), by March 31, 2024. In this respect, Regulated Entities that were authorised or appointed to act as External Managers by March 31 2024, but have not made use of their authorisation must also submit the Form. 1.2 The steps that the Regulated Entities will have to follow, for the successful submission of the Form to the TRS, can be found here. Upon submission, the Regulated Entities are responsible to ensure that they have received a feedback file, i.e. an official submission confirmation dispatched by the TRS, in the Outgoing directory. 1.3 The feedback file will either contain a NO ERROR indication or, in case that an error(s) has occurred during submission, it will contain the description of the error(s). In case of any

2 errors detected during submission of the Form, Regulated Entities must review the Form and ensure that all errors, are addressed and corrected, before they digitally sign (only applicable for the Excel files) and re-submit the Form. The Form is regarded as being successfully submitted to CySEC, only when a NO ERROR indication feedback file is received. 2. Important information when completing the number of Undertaking of Collective Investments (UCIs) For the purposes of completing the Form, please note that when questions require information about the number of UCIs, the sub-fund(s) of an umbrella fund, should be considered as fund(s). This affects: • Section A (Question 2, 4.A.2, 4.B.2) • Section C • Section G • Section J • Section K • Section L • Section M Examples:

1. A Regulated Entity has one UCI under management, which has three sub-funds. The answer to question 2.2 (Section A) is three.
2. A Regulated Entity has one UCI under management, which does not have sub-funds. The answer to question 2.2 (Section A) is one.
3. A Regulated Entity has two UCIs under management, of which one has three sub-funds, and one with no sub-funds. The answer to question 2.2 (Section A) is four.

3. Deadline for the submission of the Form 3.1. The Form, must be successfully submitted electronically, via the CySEC’s Transaction Reporting System (‘TRS’) by Tuesday, April 30, 2024, the latest. 3.2. CySEC wishes to emphasise the importance of meeting the deadline set, for successful submission of the Form. 3.3. Failure to comply with the above promptly and duly, may bear the administrative penalties of section 37(5) of the CySEC Law. It is further noted that CySEC will not send any reminders, to those who fail to comply promptly and duly.
4. General Comments for the Form 4.1. The Form will be available only in the English language. 4.2. Reporting entities are required to report data in Euro, rounded to the nearest unit. 4.3. Please always ensure that you have the latest version of the Form, i.e. Version 21. 4.4. Instructions on the completion of the Form can be found in the ‘instructions’ worksheet of the Form.

3 4.5. Before submitting the Form, please ensure that all validation tests that are contained in the Form (Sections A, B, C, D, E, F1, F2, F3, F4, G, H, I, J, K, L, M and Validation Tests Worksheet) are TRUE (Green Colour). 5. Method of creating, signing and submitting the Form to CySEC After populating the required Excel fields of the Form, the Regulated Entities should name their Excel file in accordance to the following naming convention: Username_yyyymmdd_QST-MC The information below explains the naming convention: (1) Username – is the username of the TRS credentials, which should already be in the possession of the Regulated Entities that have previously submitted any electronic file to the TRS system. This codification should be entered in capital letters. Regulated Entities, that have not previously requested the TRS credentials, can do so by referring here, where further information is provided about the TRS. (2) yyyymmdd – this denotes the end of the reporting period of the Form. In this case the Form should have a 20240331 format. Future Forms will have different reporting periods. (3) QST-MC – this is the coding of the Form, that it remains unchanged and should be inserted exactly as it appears. (4) The Excel® file must be of 2007 version and onwards. Excel will add the extension .xlsx as soon as it is saved. This extension should not, under any circumstances, be inserted manually. 6. Support 6.1. Queries on how to complete the fields of the Form Should you have any queries on the completion of Form QST-MC, please submit them only in writing, any day PRIOR to Tuesday, April 23, 2024, by sending an email to the address riskstatistics.fundmgrs@cysec.gov.cy. All email communication should include in the subject line, the Regulated Entity’s full name and the TRS coding. 6.2. Technical Queries on digitally signing and submitting the Form For technical matters on digitally signing and submitting the Form, the REs are advised to frequently visit the CySEC’s website at the specified section. For further clarifications, the REs are requested to use the electronic address information.technology@cysec.gov.cy. All email communication with CySEC should include, in the subject, the REs full name and the TRS coding. Yours sincerely, George Karatzias Vice Chairman Cyprus Securities and Exchange Commission