On 29 November 2023, the CSSF published an update to the FAQ concerning CSSF Circular 22/811 on UCI
Administrators ("UCIA Circular") by adding
questions 3.3, 4 and 5.
As regards administration functions, the CSSF clarifies that
when the UCIA is responsible for the net asset value
("NAV") calculation and accounting
function, the sole compilation/input of accounting information is
not sufficient to comply with the UCIA duties, in accordance with
the UCIA Circular. As an example, a UCIA should be in a position to
challenge the NAV calculation and/or accounting related information
provided by a delegate. In this respect, the CSSF further clarifies
that non-substantial UCIA (i.e., letter-box entity) must be
considered as contravening the conditions which the UCIA is
required to meet in order to obtain and maintain its authorisation.
In this context, delegation models leading to a UCIA solely
compiling accounting information received from third parties or
delegates are
