FUND NEWS Financial Services / Regulatory and Tax / Issue 115
Developments in May 2014 Investment Fund Regulatory and Tax developments in selected jurisdictions
European Union 3 ESMA consults on MiFID II and MiFIR 4 EC issued a proposal for the recast of Shareholders Directive concerning assets managers and institutional investors 5 EU Audit Reform published 6 ESMA publishes 8th updated Q&A on EMIR implementation Ireland 8 Central Bank Publishes 9th Edition of AIFMD Q&A 8 Central Bank Publishes 2nd Edition of UCITS Q&A 8 CRR & CRD IV for MiFID Investment Firms 5 Central Bank Updates its Prospectus Handbook & Prospectus FAQ 8 DJEI Consultation on the Proposed EU Directive on Shareholders’ Rights 9 IMF Report – Detailed Assessment of Observance of IOSCO Objectives and Principles of Securities Regulation 9 Key Dates Reminder Switzerland 10 Automatic exchange of tax information International 10 Joint Forum report point of sale disclosure in the insurance, banking and securities sectors
Tax News European Union 11 Soon a “scaled down” version of the Financial Transaction Tax Directive? International 11 ECD – Automatic exchange of tax information Declaration; similarities to FATCA 12 New home for online Luxembourg fund regulation library 12 KPMG reportingfunds.co.uk
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European Union ESMA consults on MiFID II and MiFIR On 22 May 2014 the European Securities and Markets Authority (ESMA) launched the consultation process for the implementation of the revised Markets in Financial Instruments Directive (MiFID II) and Regulation (MiFIR). This is the first step in the process of translating the MiFID II/MiFIR requirements into applicable detailed rules. MiFID II/MiFIR introduces changes that will have a large impact on the EU’s financial markets, these include transparency requirements for a broader range of asset classes; the obligation to trade derivatives onexchange; requirements on algorithmic and high-frequency-trading and new supervisory tools for commodity derivatives. It will also strengthen protection for retail investors through limits on the use of commissions; conditions for the provision of independent investment advice; stricter organisational requirements for product design and distribution; product intervention powers; and the disclosure of costs and charges.
MiFID II/MiFIR contains over 100 requirements for ESMA to draft Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS), and to provide Technical Advice to the European Commission to allow it to adopt delegated acts. In order to ensure that MIFID II achieves its objectives in practice, ESMA published the following documents: • C onsultation Paper on MiFID/ MiFIR Technical Advice – ESMA needs to deliver this advice to the European Commission by December 2014 and is therefore subject to a condensed consultation process for this paper; and • Discussion Paper on MiFID/MiFIR draft RTS/ITS – this will provide the basis for a further consultation paper on the draft RTS/ITS which is expected to be issued in late 2014/ early 2015. The closing date for responses to both papers is Friday 1 August. The main issues covered in the Discussion and Consultation Paper are divided into those addressing the structure, transparency and regulation of financial markets, and those aimed at strengthening investor protection.
Financial Markets Structure, Transparency and Regulation The main proposals in this area cover the following issues – • enhanced transparency and trading obligations – increasing pre- and post-trade transparency for many categories of instruments, e.g. shares, ETFs, certificates, bonds and derivatives, limitations to trade shares OTC and new obligations to trade derivatives on trading venues; • micro-structural issues – refining the definition of high frequency trading and direct electronic access and specifying the requirements for operating in the market using algorithmic techniques; • data publication and access – issues related to the development of the consolidated tape including requirements for tape providers, approved publication arrangements and reporting mechanisms, and the definition of a reasonable commercial basis for data sales; and the access to CCPs, trading venues and benchmarks; • other organisational requirements for trading venues; and • commodity derivatives – new regulatory tools, including position limits.
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The main proposals relating to the improved protection of retail investors include technical advice on-
ESMA will hold three public hearings about secondary markets, investor protection and commodity derivatives issues on Monday 7 and Tuesday 8 July. Further details on the hearings will be published on ESMA’s website.
• inducements – new limitations on the receipt of commissions (inducements); • independent advice – clearly distinguishing independent from non-independent advice; • product governance – requirements on the manufacture and distribution of financial products including target market and risk identification; • product intervention/banning – introducing powers for both ESMA and national regulators to prohibit or restrict the marketing and distribution of certain financial instruments; and • improved information on costs and charges – requirements to provide clients with details of all charges related to their investment (relating to both the investment service and the financial instrument provided) so they can understand the overall cost and its effect on their investment’s return. • the draft regulatory technical standards relate to the authorisation of investment firms, passporting, and certain best execution obligations.
The text of the Consultation Paper is available at the following web link http://www.esma.europa.eu/system/ files/2014-549_-_consultation_paper_ mifid_ii_-_mifir.pdf
and the Discussion Paper can be found at the following web link. http://www.esma.europa.eu/system/ files/2014-548_discussion_paper_ mifid-mifir.pdf
EC issued a proposal for the recast of Shareholders Directive concerning assets managers and institutional investors On 9 April 2014, the European Commission issued a proposal to amend the existing Shareholder Rights Directive 2007/36/EC with the objective of improving the governance of EU listed companies. The proposal aims at (i) enhancing transparency and (ii) engaging shareholders and the main implications for investment management are:
– Increased transparency for asset managers and for institutional investors Asset managers and institutional investors will be required to develop a policy on shareholder engagement on a “comply or explain” basis. The engagement policy should provide for an approach to monitoring investee companies, how to exercise voting rights and how to manage any conflicts of interest. Annual disclosure of how the policy has been implemented is foreseen. Institutional investors must disclose how their equity investment strategy is aligned with the profile and duration of their liabilities and how it contributes to the medium to longterm performance of their assets. Where asset managers invest on behalf of institutional investors, asset managers will have to report on a halfyearly basis on whether their investment strategy complies with the arrangement made. – Transparency of proxy advisors Adequate measures shall be put in place by proxy advisors to ensure that their voting recommendations are accurate and reliable, based on existing information and that they are not affected by any conflict of interest or conflicting business relationship. Any conflict of interest or business relationship that could eventually influence the preparation of the voting recommendations shall be disclosed to their clients. The text of the proposal is available at the following web link. http://eur-lex.europa.eu/legalcontent/EN/TXT/?qid=139868048875 9&uri=COM:2014:213:FIN
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EU Audit Reform published The European Parliament and Council have approved a Regulation and a Directive intended to reform the audit market in the EU that was published in the Official Journal on 27 May 2014. The key requirements of the new legislation are summarised below: 1. Public Interest Entities (PIEs). The Regulation affects the statutory audits of PIEs. The PIE definition captures all EU entities, irrespective of size, that (i) have securities listed on a regulated market, are (ii) credit institutions or (iii) insurance undertakings. Member States may also expand the PIE definition to include other entities. 2. International Standards on Auditing (ISAs) The European Commission is empowered to adopt ISAs within the EU.
may also issue guidelines regarding the provision of tax and valuation services if a Member State exercises its option to permit these. The Regulation requires a written report by the statutory auditor to the Audit Committee. 5. Restrictions on Non-Audit Services (NAS) to audited entities The Regulation contains a list of services which the statutory auditor of a PIE and all members of the statutory auditor’s network are prohibited from providing to the PIE itself or to that PIE’s EU controlled undertakings or its EU parent undertaking. The NAS prohibitions include, inter alia, tax compliance, tax advice, corporate finance and valuation services. Member States also have the option to allow certain tax and valuation services on condition that they do not have a direct effect on the financial statements or, if they do, that the effect is immaterial.
3. Auditor reporting to shareholders The Regulation contains expanded auditor reporting requirements aimed at enhancing investors’ understanding of the audit process including critical judgements made during the audit.
The prohibitions in the Regulation are far more extensive than the rules currently in place in many EU Member States today and go well beyond the international independence requirements in the IESBA Code or indeed the SEC’s independence rules in the US.
4. Audit Committees Audit Committee approval is required for all permissible nonaudit services after having assessed the threats and safeguards to auditor independence. Audit committees
The prohibitions also extend to the financial year immediately preceding the appointment of the statutory auditor (“clean period”) with regard to designing and implementing internal control or risk procedures related to the
preparation and/or control of financial information or designing and implementing financial information technology systems. Permissible NAS are also “capped” if they exceed 70% of the statutory audit fee. Member States have the option to add to the list of prohibited NAS and apply a cap that is lower than 70%. 6. Mandatory Firm Rotation (MFR) Every company that falls within the PIE definition is required to rotate their auditors after a ten year period and Member States are allowed to adopt a shorter period. The Regulation also grants Member States the option to allow PIEs to extend the rotation period to (i) a maximum of 20 years if a public tender takes place on expiry of the 10 year period or (ii) to a maximum of 24 years where a joint auditor is appointed. Non-EU groups that have an EU based PIE in their group structure will be required to rotate the auditors of those subsidiaries. 7. Transition arrangements for the legislation The regulation comes into effect on 16 June 2014 and EU Member States are required to apply the legislation no later than two years thereafter. There are specific transitional provisions for the mandatory audit firm rotation requirements which come into effect progressively starting in 2016.
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ESMA publishes 8 th updated Q&A on EMIR implementation On 21 May 2014 the European Securities and Markets Authority (ESMA) issued updated Questions and Answers (Q&A’s) on the implementation of the European Markets Infrastructure Regulation (EMIR). These updated Q&A’s clarify, among others: • When a derivative contract is concluded by a sub-fund of an umbrella fund that is a UCITS or AIF, the counterparty should be the sub-fund, identified by a LEI for reporting purposes, and not the umbrella fund. Otherwise the umbrella fund should be reported as LEI with the sub-fund identified as beneficiary.
• The classification of counterparties covered by the AIFMD. Securitisation SPVs and SPVs created by real estate and private equity AIFs). • The classification as financial counterparty of AIFs (EU and nonEU) managed by an authorized or registered AIFM. The definition of a financial counterparty should be understood as covering the following entities: 1. EU AIFs managed by authorised EU AIFMs. 2. E U AIFs managed by registered EU AIFMs. 3. N on-EU AIFs managed by authorised EU AIFMs.
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4. Non-EU AIFs managed by registered EU AIFMs. 5. E U AIFs managed by authorised non-EU AIFMs (subject to extension of the passport). 6. Non-EU AIFs managed by authorised non-EU AIFMs (subject to extension of the passport). Non-EU AIFs marketed in the Union by non-EU AIFMs (both below and above the thresholds of Article 3(2) of the AIFMD) under Article 42 of the AIFMD should be considered as third-country entities because they are neither undertakings established in the Union nor are they managed by authorised or registered AIFMs. EU AIFs marketed in the Union without
a passport by non-EU AIFMs (both below and above the thresholds of Article 3(2) of the AIFMD) under Article 42 of the AIFMD should be considered as non-financial counterparties because they are undertakings established in the Union and they are not managed by authorised or registered AIFMs. • A contract between a financial counterparty (FC) and another counterparty may be eligible for an intragroup exemption if the other counterparty, while not consolidated under the CRD, is part of the same consolidated nonfinancial group.
• Any non-EU central bank listed under Article 1(4) of EMIR is exempted, while any central banks not included in the list is to be treated as third country entity that would be a non-financial counterparty if it were established in the EU. • A participant of a trading venue, which is also a clearing member of the relevant CCP, cannot deny its clients the protections of segregation and portability, where it executes trades on behalf of its clients and subsequently clears those trades with the relevant CCP.
The text of the Q&A is available at the following web link. http://www.esma.europa.eu/system/ files/2014-550.pdf
An updated public registry regarding new CCP authorizations is available under the post-trading section of this web link http://www.esma.europa.eu/page/ Registries-and-Databases
Fund News / Issue 115 / Developments in May 2014 / 7
Ireland Central Bank Publishes 9 th Edition of AIFMD Q&A
Central Bank Publishes 2nd Edition of UCITS Q&A
CRR & CRD IV for MiFID Investment Firms
On 2 May 2014 the Central Bank of Ireland published a ninth edition of the AIFMD Q&A. Question ID 1054 has been amended to confirm that QIFs that are now transitioning to QIAIFs but which were previously granted a derogation to invest in a linked AIF are not required to apply to the Central Bank in order to continue to avail of this derogation notwithstanding that it is no longer available.
On the 30 May 2014, the Central Bank published a second edition of the UCITS Q&A covering the permitted markets for UCITS and clarifying that the Central Bank will not object if UCITS (or AIFs) provide for investment of up to 100% of their net assets in securities and instruments issued or guaranteed by the government of the People’s Republic of China.
The Central Bank has finalised its Implementation Notice on Competent Authority Discretions and Options in CRD IV and CRR (the “Notice”) which outlines the Central Bank’s policies on discretions of specific relevance to MiFID firms and provides information on the impact of certain provisions of CRR and CRD IV on MiFID firms.
A new question, Question ID 1071, has been included confirming that once an AIF becomes subject to the AIF Rulebook derogations which have been granted to the AIF under the NU Series of Notices will no longer be valid or relevant, other than in the case outlined in Question ID 1054.
The second edition of the UCITS Q&A is available at the following link: http://www.centralbank.ie/ regulation/industry-sectors/funds/ ucits/Documents/UCITS%20QA%20 NO%202_%20FINAL%2030%20 MAY%202014.pdf
Derogations from the AIF Rulebook will be considered on a case-by-case basis where a detailed and comprehensive rationale supporting the request for the derogation has been provided. The ninth edition of the AIFMD Q&A is available at the following link: http://www.centralbank.ie/ regulation/marketsupdate/ Documents/FINAL%20CLEAN%20 -%209th%20edition%20QA.pdf
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Please see the following link for further information: http://www.centralbank.ie/regulation/industry-sectors/credit-institutions/Documents/Implementation%20of%20Competent%20 Authority%20Discretions%20 and%20Options%20in%20CRD%20 IV%20and%20CRR.pdf
Separately, the Central Bank has published guidance for investment firms on the procedure for uploading CRD IV XBRL files to the Online Reporting system (“ONR”) which is available at the following link: http://www.centralbank.ie/ regulation/industry-sectors/ investment-firms/mifid-firms/ Documents/CRD%20IV%20ONR%20 XBRL%20File%20Upload%20 User%20Procedure.pdf
Central Bank Updates its Prospectus Handbook & Prospectus FAQ
DJEI Consultation on the Proposed EU Directive on Shareholders’ Rights
The Central Bank’s Prospectus Handbook has been updated to refer to the new regulatory technical standards (“RTS”) on prospectus supplements arising from Commission Delegated Regulation (EU) No 382/2014 of 7 March 2014.
The proposed EU Directive on Shareholder’s rights will affect asset managers, institutional investors, investment intermediaries, listed companies, proxy advisors as well as shareholders. The Department of Jobs, Enterprise and Innovation (“DJEI”) has issued a consultation seeking the views of interested parties on the proposed Directive. The consultation will run until 13 June 2014 and is available at the following link:
Please see the following link for further information: http://www.centralbank.ie/ regulation/marketsupdate/Pages/ SecuritiesMarkets.aspx
Separately, the Central Bank has published FAQ guidance on the Prospectus Regulation which is available at the following link: http://www.centralbank.ie/ regulation/marketsupdate/ Documents/FAQ%2023%20May%20 2014.pdf
Key Dates Reminder • 13 June 2014 Deadline for responses to the DJEI on the proposed Directive on shareholder’s rights. See above. • 30 June 2014 The end of the first reporting period for AIFMs reporting quarterly and semi-annually. Period to be reported by 11 September 2014. See Issue 113 of Fund News (March 2014). • 30 June 2014 Deadline for filing the “Investment Funds Annual Sub-Fund Profile Return” on the Central Bank’s Online Reporting System (“ONR”).
http://www.djei.ie/publications/ commerce/2014/EU_Directive_ Proposal_Shareholders_ Rights_2014_Consultation.pdf
IMF Report – Detailed Assessment of Observance of IOSCO Objectives and Principles of Securities Regulation. This report was issued on 30 May 2014. It concludes that the Central Bank of Ireland demonstrates a high level of implementation of the International Organization of Securities Commissions (IOSCO) Principles for markets supervision. Please see the following link for details of the report: http://www.imf.org/external/pubs/ cat/longres.aspx?sk=41581.0
Fund News / Issue 115 / Developments in May 2014 / 9
Automatic exchange of tax information
Joint Forum report point of sale disclosure in the insurance, banking and securities sectors
The Swiss Federal Council adopted draft negotiation mandates for introducing the new global standard for the automatic exchange of information in tax matters with partner states. The relevant parliamentary committees and cantons will be consulted on the draft mandates in the next few months and they should definitively be adopted in the next autumn. More information is available via the following link: https://www.news.admin.ch/ dokumentation/00002/00015/index. html?lang=en&msg-id=53050
The Joint Forum (Basel Committee on banking Supervision, International Organisation of Securities Commissions, International Association of Insurance Supervisors) issued a joint report in April 2014 on point of sale (POS) disclosure for retail investment products in the insurance, banking and securities sectors. They identified key sectoral and interjurisdictional differences in the requirements across the sectors, on elements such as format and content of disclosures which makes product comparison difficult. The Joint Forum report contained the following 8 recommendations for use by policy makers and supervisors on point of sale disclosures: 1. Implement a concise written or electronic POS disclosure document. 2. Provide POS disclosure documents free of charge, before the time of purchase. 3. Disclose key characteristics including costs, risks and financial benefits or other features of a given product and any underlying or referenced assets, investments or indices, irrespective of the financial sector from which the products are derived.
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4. The POS disclosure document should be clear, fair, and not misleading and written in a plain language designed to be understandable by the consumer. 5. The POS disclosures should contain the same type of information to facilitate comparison. 6. Key information regarding product shall be concise, and provide links to other information. 7. Allocation of responsibility for preparing, making available and/or delivering the POS disclosure document should be clearly established. 8. Each jurisdiction should consider how to use its capabilities and powers to implement the POS disclosure given its regulatory regime. The text of the Joint Forum report can be found at the following web link. http://www.iosco.org/library/ pubdocs/pdf/IOSCOPD439.pdf
European Union Soon a “scaled down” version of the Financial Transaction Tax Directive? On 6 May 2014 the ECOFIN addressed the proposal for a Directive on a Financial Transaction Tax (FTT) in 11 EU Member States. Although the details of the proposal are still under discussion, it appears that participating Member States would like to implement a scaled down version of the original proposal as from 2016
International A financial institution could be deemed established in a participating Member State in a variety of circumstances, including by being a counter-party to a transaction with a financial institution that was actually established in such a Member State, or where the instrument was issued by an entity so established. These rules have proved controversial and led to a legal challenge by the UK government that they infringed EU law. This action was rejected by the CJEU on procedural grounds on 30 April 2013.
Background ECOFIN position On 14 February 2013, the EU Commission issued a revised proposal for a Directive to introduce a common FTT in the 11 Member States concerned (Austria, Belgium, Estonia, France, Germany, Greece, Italy, Portugal, Slovakia, Slovenia and Spain). This was largely based on the original proposal, but with revisions to reflect the fact that not all EU Member States would apply the tax. Scope of the FTT as proposed in 2013 Under the proposal as drafted by the EU Commission in February 2013, the tax would be imposed on transactions involving one or more financial institutions. It would apply to all kinds of financial instruments, such as shares, bonds and derivatives. The FTT rate proposed was a minimum rate of 0.1%, or 0.01% for derivatives. The tax would be levied on financial institutions established (or deemed to be established) in one of the participating 11 Member States.
Notwithstanding the opposition shown by the non-participating Member States, the 11 participating Member States are determined to implement the FTT as from 2016. The tax will be given a narrower scope than originally proposed and will, initially, be applied only to shares and certain derivatives. The participating Member States were also urged to keep the other Member States informed of any developments, since this tax will impact both participating and non-participating Member States. Next steps The political will to proceed with this initiative is continuing and it now seems more likely that an agreement will be reached on the broad design of the proposal. It will then be up to the EU Commission to draft a new proposal, taking into account the many technical issues that have been discussed between the participating Member States. The form of this new proposal is likely to be key in the UK’s decision whether or not to launch a second legal challenge.
OECD – Automatic exchange of tax information Declaration; similarities to FATCA On 6 May 2014 the Organisation for Economic Co-operation and Development (OECD) announced that a declaration for the automatic exchange of tax information was adopted by all 34 OECD member countries as well as a number of other countries. According to the OECD release, bank secrecy for tax purposes will come to an end as countries and major financial centers commit to an automatic exchange of information between jurisdictions. The new global standard draws extensively on earlier work of the OECD in the area of automatic exchange of information, and incorporates progress made within the European Union, as well as global antimoney laundering standards, with the intergovernmental implementation of the U.S. FATCA rules having acted as a catalyst for the move towards automatic exchange of information in a multilateral context. With a new global standard on automatic exchange of information, countries will obtain all financial information from their financial institutions and exchange that information automatically with other jurisdictions on an annual basis. Commentary on the new standard and other measures to implement the information exchanges will be delivered in September 2014. You may find the text of the declaration under the following link: http://www.oecd.org/mcm/MCM2014-Declaration-Tax.pdf
Fund News / Issue 115 / Developments in May 2014 / 11
New home for online Luxembourg fund regulation library From May onwards, kpmgregulapedia. lu will become the KPMG Regulatory Scout Library. While users will still be able to find all their fund regulations with just one click of the mouse, the move brings updates to the platform which will see the library form part of a wider suite of services to assist fund managers in dealing with regulatory changes. This web-based library pulls together European and Luxembourg fund regulations from various sources. With just one click on the name of the desired regulation, users are directed to a list of associated circulars, laws, consultation papers and other legal texts. For each regulation, the documents are grouped according to issuing institution with the most recent document at the top of the list. A powerful search function scans the content of all the documents in the library. The library is now housed on the KPMG Regulatory Scout website: a portal offering a range of regulatory tools and both online and offline support for fund managers. Start searching today at www.kpmgregulatoryscout.lu/ library/
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KPMG reportingfunds.co.uk In response to investment management industry demands, KPMG’s technology and tax teams have joined forces to create KPMG reportingfunds.co.uk, a central repository for storing tax reports provided by offshore funds. The cloudbased solution was designed and built by KPMG’s own award-winning1 application development team called KWorks. Major fund managers have already published historic reports on the repository and these are available to view. Over the course of the next year and the next reporting cycle we expect to have the vast majority of funds represented – prior to launch, we secured agreement in principle from over half of the total population. We look forward to working with funds, administrators, platforms and wealth managers to ensure that the repository is as useful as it can be.
Potential benefits for investors
How it works
For no charge, UK tax paying investors can search for offshore funds and access reports uploaded by the fund managers.
End investors can register to access reports via www. kpmgreportingfunds.co.uk. Reports can be searched over a specific range of dates and by a number of criteria including fund name, share class name or ISIN. Intermediaries can access the same level of information for free for a trial period.
• UK tax payers will no longer have to search fund managers’ separate websites to access information that they need to complete their tax returns. • The repository stores historic information – back to the start of the UK’s tax reporting regime. • Clear guidance notes are provided to assist investors in understanding the information and completing their tax returns. Potential benefits for intermediaries The repository is being licensed to professional intermediaries to enable them: • to have full access to the repository; • to maintain bespoke portfolios; • to receive alerts; • to export information.
Evolving Investment Management Regulation Light at the end of the tunnel? June 2013 kpmg.com
Evolving Investment Management Regulation
Fund managers can contact admin@ kpmgreportingfunds.co.uk on behalf of funds that have reporting status. The lead contact, the Fund Principal, will then receive a tailored invite to participate – this enables them to invite others to contribute and/or approve the information. The information will not be published until the fund or fund manager approves the reports.
Schweizerisches Recht der Kollektiven Kapitalanlagen
Swiss Financial Services Newsletter: Special Edition Investment Management
Intermediaries can also email admin@ kpmgreportingfunds.co.uk and the team will be in touch to discuss specific requirements. Frontiers in Finance For decision-makers in financial services April 2014
Potential benefits for fund managers
Cyber crime: Insurers in the firing line Page 6
Rebuilding and reinforcing risk data infrastructure Page 16
Frontiers in Finance
For no charge, funds and fund managers can upload reports. • Those who use KPMG reportingfunds.co.uk will not need to post reports on their own website. • Use of the repository enables them to control the process as they will receive notifications when deadlines approach. • Fewer investor queries can be expected.
Governance strategies for managing the data lifecycle: Knowing when to fold versus hold and protect Page 12
Frontiers in Finance
* Management Consultancies Association award for technology 2012
Fund News / Issue 115 / Developments in May 2014 / 13
Zurich Markus Schunk Partner T: +41 58 249 36 82 E: firstname.lastname@example.org
Astrid Keller Partner T: +41 58 249 28 82 E: email@example.com
Pascal Sprenger Director, Legal T: +41 58 249 42 23 E: firstname.lastname@example.org
Christoph Groebli Partner T: +41 58 249 29 76 E: email@example.com
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Lugano Lars Schlichting Partner, Legal T: +41 58 249 32 59 E: email@example.com
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. © 2014 KPMG Holding AG/SA, a Swiss corporation, is a member of the KPMG network of independent firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss legal entity. All rights reserved. Printed in Switzerland. The KPMG name and logo are registered trademarks.
Issue 115 of Fund News covers the ESMA consultation on MiFID II detailed rules, the recent update of the EMIR Q&A as well as the impact of t...