CSSF Publishes New Mandatory EMIR Questionnaire For Investment Fund Manager

August 2018 has seen the Commission de Surveillance du Secteur Financier (CSSF) publishing a new questionnaire regarding compliance with the European Market Infrastructure Regulation (EMIR). An update to this questionnaire was published in September 2018.

Detailed requirements

This questionnaire becomes a mandatory document required for the authorization as new Alternative Investment Fund Manager (AIFM), Undertakings for the Collective Investment of Transferable Securities (UCITS) Management Company (ManCo) or Chapter 16 ManCo. For reasons of comprehensiveness, the questionnaire has also been sent to existing Investment Fund Managers (IFMs).

In the document, IFMs have to disclose their EMIR classification as well as the type of derivatives used as investment product. Afterwards, IFMs are questioned regarding their procedures to ensure that funds under their management comply with EMIR obligations (namely reporting, clearing...