CSSF FAQs On AIFMs And Non-AIFs SIF And SICARs: PRIIPs Impacts

On 6 July 2017 the CSSF published an updated version of its Frequently Asked Questions (FAQ) document on alternative investment fund managers (AIFM) and created a FAQ for SIFs and SICARs which do not qualify as AIFs.

The AIFM FAQ's latest issue highlights the impact of the PRIIPs Regulation on Luxembourg AIFs in the new Section 23. It clarifies the following aspects under points 23.a) to 23.q):

• The obligation for Luxembourg AIFs advised on, offered or sold to retail investors to have in place a PRIIPs KID from 1 January 2018;
• The applicability until 31 December 2019 of the exemption provided by Article 32(2) of the PRIIPs Regulation (the exemption of Article 32(2)) to have in place a PRIIPs KID for Luxembourg AIFs sold to retail investors that already issue a UCITS KIID under condition of the related update of the prospectus.;