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Liquidity management tools and swing pricing services

Support in meeting European Securities and Markets Authority (ESMA) requirements

We help design, implement, review, and operate liquidity management tools (LMT) and anti-dilution tools (ADT) frameworks that align with ESMA’s regulatory technical standards (RTS) and guidelines. Our approach combines market best practices, robust governance, and quantitative analysis, tailored for UCITS and open-ended alternative investment funds (AIFs)

Advisory, implementation and maintenance support for your liquidity management tools program

Recent ESMA RTS and guidelines on liquidity management tools under UCITS and AIFMD set clear expectations for selection and calibration. Our team supports the design, review, and maintenance of LMT frameworks, ensuring they remain compliant, robust, and effective.

List of LMTs available to UCITS/Open-ended AIFs

The directive (EU) 2024/927 categorizes available LMTs into Anti-Dilution Tools, Quantitative LMTs and Other LMTs.

UCITS and AIFMs managing open-ended AIFs are expected to select at least two appropriate LMTs from the list below, which is taken directly from this Directive:

  1. Suspension of subscriptions, repurchases, and redemptions: Temporarily block the capital activity of the fund’s units or shares.
  2. Redemption gate: Temporary and partial restriction of the right of unit-holders or shareholders to redeem their units or shares, allowing investors to only redeem a certain portion of their units or shares.
  3. Extension of notice periods: Extending the period of notice that unit-holders or shareholders must give to fund managers, when redeeming their units or shares.
  4. Redemption fee: An additional fee, within a predetermined range that takes account of the cost of liquidity, that is paid to the fund by unit-holders or shareholders when redeeming units or shares, and to protect unitholders or shareholders who remain in the fund from being unfairly disadvantaged. 
  5. Swing pricing: A pre-determined mechanism by which the net asset value of the units or shares of an investment fund is adjusted by the application of a factor (“swing factor”) that reflects the cost of liquidity to protect unitholders or shareholders who remain in the fund.
  6. Dual pricing: A pre-determined mechanism by which the subscription, repurchase and redemption prices of the units or shares of an investment fund are set by adjusting the net asset value per unit or share by a factor that reflects the cost of liquidity. This leads to the fund having a different net asset value per unit for purchase and for sale.
  7. Anti-dilution levy: A fee that is paid to the fund by a unit-holder or shareholder at the time of a subscription, repurchase or redemption of units or shares, that compensates the fund for the cost of liquidity incurred because of the size of that transaction. 
  8. Redemption in kind: transferring assets held by the fund, instead of selling them and giving the cash to investors, to meet redemption requests of unit-holders or shareholders.
  9. Side pockets: Separating certain assets, whose economic or legal features have changed significantly or become uncertain due to exceptional circumstances, from the other assets of the fund. 

Note: Tools 5 (Swing pricing) and 6 (Dual pricing) cannot be selected alone.

For authorized money market funds, only one liquidity management tool may be selected.

 

Our services

Below is a list of our services, fully aligned with ESMA RTS and guidelines.

  • Benchmarking market practices to define the most suitable solution based on each setup.
  • Defining applicable governance, roles and responsibilities.
  • Executing quantitative analysis of the funds in scope to define the calculation methodology.
  • Performing project management assistance with regards to the implementation.
  • Benchmarking market practices to identify potential competitive gaps.
  • Operating a gap analysis of the governance currently in place to identify risks of non-compliance. For instance, Deloitte can leverage on our industry proven template of swing pricing policy.
  • Analysing the current calculation methodology to improve the accuracy of the parameters computed.
  • Back-testing the values historically used to assess the dilution avoided.
  • Assessment of the significance of market impact.
  • Periodically compiling the dilution adjustment, such as swing factors.
  • Periodically compiling the dilution threshold, such as swing thresholds.
  • Conducting periodic back-testing reviews to assess the effectiveness of the LMT used.