SUBMISSION OF CLOSING DOCUMENTS AND FINANCIAL INFORMATION BY INVESTMENT FUND MANAGERS – FAQ

1. Legal Context and Applicability

• The FAQ complements Circular CSSF 19/708, which mandates the exclusive electronic submission of specific closing documents and financial information via a secure infrastructure approved by the CSSF.

• Entities covered include:

  • Management companies under Chapter 15 of the 2010 law (UCITS managers),

  • Management companies under Article 125-1 or 125-2 of Chapter 16,

  • Investment companies without a designated management company (“SIAGs”),

  • Alternative Investment Fund Managers under the 2013 law (“AIFMs”),

  • Internally managed alternative funds (“FIAAGs”).

2. Key Topics Addressed

The FAQ is structured into two main parts:

• Part A: Closing Documents

  1. Which documents are required, depending on the IFM’s authorisation (A.1).

  2. Procedures for transmitting closing documents (A.2).

  3. Required formats for submission (A.3).

  4. Required file naming norms and document types (A.4).

  5. Submission deadlines (A.5).

  6. Requirements for quarterly or ad hoc documentation (A.6).

• Part B: Financial Information

  1. Required financial information and applicable deadlines (B.1).

  2. General principles for preparing financial information (B.2).

3. Submission Modality, Formats & Naming Conventions

• Only electronic submissions are accepted by the CSSF—paper documents are no longer accepted.

• The naming conventions, file types, and document codes to use are specified in the annex to Circular CSSF 19/708, and replicated in Annex I of the FAQ. It’s crucial that the document type and closing date in the file name match the content and remain consistent across related submissions.

4. Deadlines

• The FAQ lays out specific deadlines for annual, quarterly, or ad hoc documents, depending on their nature and the IFM’s authorisation—details are provided in section A.5.

5. Financial Data Submission

• The CSSF specifies which financial data to submit, along with the associated frequencies and deadlines (e.g., annual, quarterly) (B.1).

• Data must adhere to general quality principles, ensuring accuracy, coherence, and completeness (B.2).

6. Sanctions for Non-Compliance

• While not covered in the detail preview, such FAQs typically reaffirm the CSSF’s authority to impose administrative measures or penalties for late, incorrect, or non-compliant submissions.