The CSSF's new circular, 18/698, was released one month ago.
Although it will require a bit of work to implement, its aims are
pure: to create a level playing field for UCITS ManCos and AIFMs,
expanding on the existing principle-based approach but with a more
prescriptive touch. The circular was written with practical
findings on ManCo effectiveness in mind, taken from inspections and
older CSSF reports.
In an industry that is anticipating bigger volumes of business
(new funds) due to Brexit and other macroeconomic changes, the
circular, with its ambition to harmonise the field, comes at a good
time.
My team and I have been watching this regulatory landscape
evolve in the funds sector for years, (and I myself have a fair bit
of hands-on experience as the former head of a third-party AIFM in
Luxembourg), and we're intrigued by this new circular. In this
blog post we have compiled three insights about it that may not
have been completely obvious from the text itself.
