From now on, AIFM license applicants are requested to include two additional appendices in their application file. The additions came in an update to the “Application questionnaire for the set up of a fully licensed AIFM” that the CSSF issued on 20 March 2014.
From now on, AIFM license applicants are requested to include two additional appendices in their application file. The additions came in an update to the “
Referencing remuneration
The first new appendix is a table allowing for easy comparison between a company’s remuneration policy and the requirements outlined in Annex II of the AIFM law and ESMA’s Guidelines on sound remuneration. For each requirement, the reference table should include an extract of the corresponding part of the remuneration policy, the status of compliance as well as justifications for partial or non-compliance.
No delegation loophole on remuneration
If your portfolio or risk management activities are delegated, you need to explain how you’re making sure that third party providers also respect the remuneration requirements laid out in Annex II of the AIFM Law. This should include information about any other regulatory standards that they comply with, such as MiFID or the CRD package.
Stay in the loop
- April is the next important milestone: the CSSF has strongly recommended that authorisation files be submitted by this date. If you are at this stage, we also recommend these hints on tips on filling in your AIFMD authorisation application. Keep an eye on our AIF tag for more posts on this topic.
