FAQ – Circular CSSF 22/811 on UCI Administrators (UCIA)

TABLE OF CONTENTS

Definitions, abbreviations and acronyms

ICT Resources, Business Continuity and Disaster Recovery Planning

Q1.1 What type of data backup is expected of UCIAs pursuant to point 80 of the UCIA Circular?

Q1.2 Can the unit-/shareholder register be maintained by using distributed ledger technology (“DLT”)?

FAQ CIRCULAR CSSF 22/811 ON UCI ADMINISTRATORS (UCIA)

Scope

Q2.1 To which entities does the UCIA Circular apply?

Q2.2 Does the UCIA Circular apply to UCIs or IFMs having wholly delegated the UCI administration functions?

Administration functions

Q3.1 Is it required that one and the same UCIA performs all the administration functions?

Q3.2 Is the UCIA responsible for the function(s) for which it has been appointed?

Q3.3 May a UCIA responsible for the NAV calculation and accounting function solely compile/input accounting information received by delegates/third parties?

Delegation

Q4.1 Which sub-delegation models are compliant with the UCIA Circular?

Annual reporting for UCIAs

Q5.1 When do UCIAs need to submit their first annual reporting under point 7 of the UCIA Circular?

Central administration of Part II UCIs, SIFs and SICARs

Q6.1 Is the notion of “central administration” within the meaning of the 2010 Law, the 2007 Law and the 2004 Law identical to the notion of “UCI administration” within the meaning of the UCIA Circular?

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