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CSSF press release 19/49 communication regarding the results of the 2018 EMIR IFM Questionnaire

 

29 October 2019

On 14 October 2019, the CSSF published, in a press release 19/49 its findings following the questionnaire that was sent in August 2018 to Luxembourg investment fund managers (IFMs) to assess compliance with the EMIR Regulation. 


The CSSF wants IFMs to generally improve the supervision and oversight of their EMIR obligations. 

​In particular, the CSSF draws the attention of IFMs to the following points: 

  • adequate written procedures and arrangements must be in place between the IFM and its delegate; 
  • monitoring of delegates through initial and on-going due diligences should be improved; 
  • derivative contracts concluded for hedging purposes are also subject to EMIR obligations; and 
  • registered AIFMs are also in scope of EMIR. 
The CSSF has indicated that it has focused on EMIR monitoring and oversight procedures for now but that it will further assess the compliance with EMIR requirements and the quality of data of trades reported to trade repositories.
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