CSSF Circular 12/546 urgent requirements and opportunities - 27/11/2012 |
In a recent communication, the CSSF established the obligation for UCITS management companies and UCITS self-managed SICAVs to submit a file explaining how they will comply with the new circular requirements. The deadline to fulfil this obligation is 15 April 2013.
Across the various topics addressed in the new circular, 3 immediate actions should be undertaken by market participants:
1. Impact assessment: quickly identify potential deficiencies and shortcomings within your UCITS structure compared to Circular 12/546
2. Due diligence on delegated functions: delegation rules are a key concern of the circular and are being closely scrutinised by the CSSF, especially when a new sub-fund authorisation is sought
3. CSSF report: market participants should start preparing the report due by 15 April 2013, ensuring that it meets regulatory expectations
How can Deloitte help you?
- We have developed a gap analysis tool able to quickly measure the adequacy of your organisation against the new circular. The outcome of our impact assessment is a heat map clearly showing any eventual shortcomings
- Building on our extensive industry expertise, we can identify the stress points likely to influence the capacity of a third party to provide proper service. We would also identify potential counterparty risks associated with third party providers
- We can assist you in the preparation of the report needed by 15 April 2013, ensuring that all required elements of information are included and presented to the CSSF. We can also deliver this report earlier, as compliance with the circular will remove the need for legacy Promotership requirements
Please do not hesitate to contact us, should you want additional information with regards to the above views and service offering.
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Regulatory News Alert - New CSSF Circular 12/546 - Immediate requirements and opportunities
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