Fund SAQs: How can we help?

Context and objectives

On 22 December 2021, the Commission de Surveillance du Secteur Financier (CSSF) published three new Circulars (CSSF 21/788, 21/789 and CSSF 21/790) that require self-assessment questionnaires (SAQs) to improve the monitoring of investment fund managers (IFMs) and investment funds, as well as anti-money laundering and counter-terrorist financing (AML/CTF):

What does this mean for you? As an IFM you need to:

• Reconfirm the legal obligations for CSSF-regulated investment funds and Luxembourg investment fund managers as they relate to unifying the duties of réviseurs d'entreprises agréés (REA, or approved statutory auditors); and
• Carefully consider how said obligations proposed by Circulars 21/788, 21/789, and 21/790 might impact your investment funds.

The SAQ: technical and time consuming

The Board of Directors of the fund are ultimately responsible for accurate self-assessment questionnaires (SAQs). UCITS funds have to be submitted via eDesk three months after fiscal year-end—at latest—while UCI part II, SIFs and SICAR must be completed in four.

Practically speaking, accurately completing a fund’s SAQ has proven to be quite difficult; it can generate a workload that requires highly technical skills, which can quickly become time consuming and drain resources.

Our Deloitte solution

Deloitte’s multidisciplinary Audit, Advisory and Consulting teams can assist you in ensuring you are in line with these Circulars and operational processes deriving from the regulation.

We can assist you across the entire chain of the SAQ data gathering, compilation, project management or technical support.

Don’t hesitate to reach out.