CSSF Data Collection on Performance Fee Models

Overview

In September 2021 the CSSF launched a new mandatory questionnaire dedicated to performance fee models applied by Luxembourg regulated funds. The new survey consists of a set of questions to be answered via eDesk, the regulator’s online portal, allowing the CSSF to monitor regulatory compliance and to collect standardised key information in relation to performance fees.

Investment fund managers (IFMs) are requested to complete the questionnaire for all Luxembourg-based UCITS and supervised alternative investment funds (AIFs) they manage. Funds and sub-funds that have been approved but not yet launched or that became inactive following the full redemption of their shares or units (and then await reactivation) also need to be declared. Funds not charging a performance fee will need to submit a negative confirmation to declare they are out of scope.

The IFM is responsible for keeping the declaration up-to-date. Once declared, all records must be updated via the portal in the event of any changes.

Starting 30 September 2021, fund managers will find a list of funds and sub-funds concerned by the new declaration when logging into the performance fee dashboard of the new eDesk module on performance fees.

For more information please visit the CSSF website.

 

Timelines

The submission deadline of the questionnaire depends on a fund’s financial year. Generally speaking, IFMs must declare their data as follows:

  • starting 30 September 2021, for funds whose financial year ends between July 2021 and December 2021;

  • starting 1 January 2022, for funds whose financial year ends between January 2022 and June 2022.

 

The deadline for the initial declaration will usually be the last day of a fund’s financial year. As an exception, for funds with a financial year ending between July and September 2021, the CSSF requires the initial declaration to be submitted by 30 November 2021.

 

Should your business be required to declare its data, please get in touch.

 

OMEA Advisors can provide assistance in collecting, drafting, and submitting your declaration in line with the new requirements.