The ESAs published today an updated version of their PRIIPs Q&A for investment funds.
Circular CSSF 21/790 introduced new requirements for Investment Fund Managers (IFMs) having investment funds supervised by the CSSF. A Self-Assessment Questionnaire (SAQ) must now be completed at each fiscal year-end of a fund. Selected answers from the SAQ will be subject to testing by the fund auditors in a Separate Report, including AML questions. The Circular is applicable since the 30th of June 2022.
The governing bodies of the fund are responsible for completing this questionnaire. UCITS have to submit the SAQ via eDesk at the latest 3 months after fiscal year-end, while UCI part II, SIFs and SICAR have 4 months to do so. RAIFs are not in scope of this circular.
The SAQ is covering inter alia, themes such as the organisation of the fund, investment compliance, asset valuation, NAV calculation process, expenses and income. The SAQ contains over 700 questions and sub-questions, the answers to which must be duly validated by the fund's governing bodies.
To assist its clients in this critical and time-consuming exercise, EFA has developed a SAQ Support Service. Reports and data are prepared for certain questions of the SAQ enabling our clients to build documented responses in the most efficient manner.
For more information on this EFA service and the applicable commercial terms, contact us !