Events listed in [ALFI] Association of the Luxembourg Fund Industry

ALFI responds to the ESMA call for evidence on the shortening of the settlement ...

ID 26463
ALFI’s response to ESMA’s call for evidence on the move to T+1/T+0 settlement cycles, dated December 15, 2023, outlines ALFI’s perspectives on the potential transition. The document touches on various aspects of the proposed shift, emphasizing the challenges faced by asset managers, especially in terms of cash management and provides a detailed analysis of the impacts on various operational processes, including matching, allocation, affirmation, ...

ALFI responds to SFDR review consultation by European Commission

ID 26404
ALFI submitted its response to the European Commission’s targeted consultation concerning the implementation of the SFDR. ALFI’s response outlines several key recommendations for enhancing the current SFDR regime: Firstly, ALFI proposes that entity level PAI disclosures be adequately addressed under the CSRD without imposing additional disclosure requirements under SFDR. ALFI contends that such duplicative measures contribute minimally to investor understanding. S ...

ALFI responds to the second ESMA’s consultation on proposed RTS/ITS on MiCA

ID 26212
ALFI responded to the second ESMA’s consultation package on Technical Standards specifying certain requirements of MiCA, provides a detailed response to ESMA regarding the proposed technical standards. The response addresses various aspects of the proposed technical standards, focusing on sustainability disclosures, coherence, complementarity, and proportionality, practical approach to assessing sustainability impacts of consensus mechanisms, optional sustainability ind ...

ALFI responds to the EU Commission’s ‘have your say’ on the proposal for a ...

ID 25536
ALFI responded to the EU Commission’s ‘have your say’ on the proposal for the proposed regulation on Financial Data Access (FiDA) and amending regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554. ALFI represents the Luxembourg asset management and investment fund community and emphasizes the importance of considering the impact of the proposed regulation on the fund industry. The document ...

ALFI statement on the conclusion of trialogue negotiations concerning the AIFMD ...

ID 25514
ALFI published as statement on the conclusion of trialogue negotiations concerning the AIFMD review, a process initiated over three years ago following various reports and consultations by the European Commission. While the primary focus was on managers of alternative investment funds, revisions to several provisions of the UCITS Directive have also ensued. **The revised directives will impose increased information requirements upon the authorization of ...

ALFI responds to EC consultation for a new system on excess withholding taxes

ID 25009
ALFI has provided its opinion on the draft Directive on the eTRC proposed by the European Commission. As a reminder, the European Commission introduced the FASTER Directive on 19 June 2023 to simplify and expedite cross-border withholding tax relief, improving efficiency and combating tax fraud. Key provisions include a common EU digital tax residence certificate, national registers for certified financial intermediaries, and relief at ...

ALFI position paper on the calibration of the depositary duties as regards the ...

ID 24891
On 11 September 2023, ALFI released a position paper addressing the calibration of depositary duties in the context of monitoring ESG investments. This paper was prompted by §46 of the ESMA supervisory briefing published in May 2022 concerning sustainability risks and disclosures in investment management (ESMA34-45-1427). The document, authored by ALFI’s Depositary Bank Forum Steering Committee and ALFI’s ad hoc ESG investment limits working ...

ALFI responds to ESAs consultation paper on DORA draft regulatory technical a) to ...

ID 24879
The ESAs launched public consultations on the first batch of policy products under the Digital Operational Resilience Act (DORA) on 19 June 2023. This includes four draft regulatory technical standards (RTS) and one set of draft ITS. These measures aim to establish a consistent and harmonized legal framework for ICT risk management, major incident reporting, and third-party risk management in the EU financial sector. ...

ALFI responds to the FSB Consultation addressing Structural Vulnerabilities from ...

ID 24833
ALFI responded to the FSB Consultation on Structural Vulnerabilities Arising from Liquidity Mismatch in OEFs. This consultation coincided with the IOSCO consultation report on Anti-dilution Liquidity Management Tools, aiming to provide guidance for the effective implementation of liquidity risk management recommendations for CIS (see ALFI’s corresponding response in eventid=22788). **ALFI appreciates the principle-based guidance that promotes convergence and good practi ...

ALFI responds to IOSCO consultation report on anti-dilution liquidity management ...

ID 24821
ALFI has responded to IOSCO’s consultation report on anti-dilution liquidity management tools. ALFI highlights that open-ended RE funds already have appropriate mechanisms in place to manage liquidity and mitigate dilution risks. These mechanisms include commitment mechanisms, redemptions paid with undrawn commitments and unencumbered cash, and the use of adjusted NAVs. The ALFI survey indicates that only 1% of Luxembourg real estate funds made use ...
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