Wednesday October 3 2018
News Source: Fund Regulation
The CSSF has published updated FAQs concerning specialised investment funds (SIFs) under the law of 13 February 2007 and investment companies in risk capital (SICARs) under the law of 15 June 2004 that do not qualify as alternative investment funds (AIFs).
Questions and Answers
1.a) Do manufacturers of Luxembourg SIFs and SICARs that do not qualify as AIFs the units of which are being advised on, offered or sold to retail investors need to draw up a PRIIPs KID?
Yes, manufacturers of Luxembourg SIFs and SICARs that do not qualify as AIFs the units of which are being advised on, offered or sold to retail investors need to have in place a PRIIPs KID as of 1 January 2018. If they choose to issue a UCITS KIID-like document as per article 2 of the law of 17 April 2018 regarding the implementation of the PRIIPs Regulation, they are exempted from the obligations of the PRIIPs Regulation until 31 December 2019 under article 32(2) of the PRIIPs Regulation, unless such deadline shall be postponed by the European Commission on the basis of the review of the transitional arrangements of the PRIIPs Regulation under article 33(1), paragraph 2.
1.b) Do the same questions and answers as mentioned under 23.b) to 23.q) of the Frequently Asked Questions concerning the Luxembourg law of 12 July 2013 on alternative investment fund managers apply to the drawing up of a PRIIPs KID by Luxembourg SIFs and SICARs that do not qualify as AIFs
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