FUND NEWS

Financial Services / Regulatory and Tax / Issue 124

Developments in February 2015 Investment Fund Regulatoryand Tax developments in selected jurisdictions

Regulatory Content

European Union 3 European Commission publishes Green Paper on

the Building of a Capital Markets Union 4 EC Consultation Document: “An EU framework

for simple, transparent and standardized securitization”

6 Council agrees on final rules regarding indices used as Benchmarks

7 Anti-money laundering: the EU Council approves the agreement with the European Parliament

8 ESMA publishes peer review on best execution supervisory practices under MiFID

8 ESMA puts FX Non-Deliverable forward classes out of scope for central clearing under EMIR

9 ESMA issues its technical advice to the European Commission on Market Abuse Regulation (MAR)

10 ESMA issues its Technical Advice to the European Commission on delegated acts of EuSEF and EuVECA Regulations . .

UK 12 Wholesale Sector Competition Review 12 Dealing Commission Feedback Statement 13 Market Abuse Controls 13 FCA fines Aviva Investors £17.6m for systems and

controls failings that led to its failure to manage conflicts of interest fairly

14 Whistleblowing in deposit-takers, PRAdesignated investment firms and insurers

14 UK Listing Authority fees: covering the cost of regulation

15 Version 3.1 of the Transaction Reporting User Pack

Ireland 16 ICAV Bill Passed 16 CBI Themed Inspections 2015 16 CBI Enforcement Priorities 2015 16 CBI – Fitness and Probity FAQ 16 CBI Report on AML 17 Speech by CBI’s Director of Markets Supervision

Switzerland 17 Switzerland: FINMA launches consultation on

FINMA Anti-Money Laundering Ordinance

Luxembourg 18 CSSF publishes description of controls performed

on submitted AIFMD reporting files

International 18 IOSCO issues the Review of Financial Benchmarks

Principles

Contents

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February 2015 together with this Green Paper.

• Widening the investor base for SMEs through the development of credit information and credit scoring to overcome the current restricted access to information on SMEs and provide investors and lenders with valuable information on their creditworthiness.

• Building a high quality securitisation market providing investors with the necessary high standards, legal certainty, transparency and comparability across securitisation instruments. Steps are already initiated in this respect with the publication of a consultation on the same day as this Green Paper (see specific article in this edition of the Fund News).

• Boosting Long-Term Investment. The European Fund for Strategic Investments (EFSI) and the European Long-Term Investment Fund (ELTIF) regulatory framework, which is expected to be published during Spring 2015, should contribute to achieving this objective, provided a suitable environment is in place.

• Developing European private placement markets that would provide a more cost effective way for firms to raise funds. However the realisation of this objective could be left to market participants as they have already taken the initiative to publish a guide on common market practices, principles and standardised documentation.

The Commission further seeks the views of stakeholders on any other

area that should be prioritised and any further actions that may help in the areas of SME credit information, ELTIFs and private placement markets.

In addition, the EU Commission has identified three challenging areas that require specific attention and are also submitted to stakeholders for consultation:

• Improving access to finance, and especially to alternative funding sources could be achieved with the following measures:

– Addressing information issues by ensuring that SMEs are made aware of the possible alternative financing solutions available.

– Improving transparency and comparability of financial information on SMEs with the development of simplified, common and high quality accounting standards, proportional to the size of SMEs.

– Improving transparency of infrastructure projects or pipelines.

– Standardisation in relation to the market rules, the transparency on product features and a consistent supervision and enforcement could also be used to a certain extent to boost certain markets. According to the Green Paper, the EU Commission would consider to focus on the covered bond market, the corporate bond market and environmental, social and corporate governance investments (“green bonds” for example).

European Commission publishes Green Paper on the Building of a Capital Markets Union

On 18 February 2015 the European Commission (EU Commission) has published a Green Paper on the Building of a Capital Markets Union to gather views of all stakeholders involved in capital markets in order to reach a fully functioning Capital Markets Union by 2019. The aim of the Capital Markets Union will be to boost job creation and growth through the development of capital markets based financing. The consideration underlying the Green Paper is that EU companies still mainly rely on bank financing compared to other jurisdictions, such as the US. In order to achieve the development of the Capital Markets Union, the EU has identified the need to overcome the following challenges:

• Reduce the reliance of the European economy on bank financing

• Improve access to financing for businesses and long-term projects

• Diversify the funding sources

• Improve market effectiveness and efficiency

The EU Commission has identified five areas where progress would bring early benefits:

• Lowering barriers to accessing capital markets by reviewing the Prospectus Directive to avoid that the prospectus requirements, approval process and content finally act as a barrier to access to capital markets. A review of this Directive has been launched on 18

European Union

Fund News / Issue 124 / Developments in February 2015 / 3

– The EU Commission also investigates the possibility to develop the cross-border potential of online financing such as peer-to-peer lending and crowd funding.

• Increasing and diversifying the sources of funding. The Consultation Paper highlights the key role played by the European Asset Management Industry in channelling investors’ money into the economy, specifically through the UCITS and AIFMD frameworks but is looking into ways to increase the institutional investors’ appetite for long-term projects but also start-ups and SMEs. It also considers to make vehicles such as EuVECA and EuSEF accessible for larger fund managers. Retail investors are also seen as an important source of funding. Though UCITS are very popular vehicles and are addressed to retail investors, the latest represent no more than 26% of investment fund ownership in the Eurozone. To increase the attractiveness of retail oriented products, it is necessary to rebuild confidence in financial market by enhancing product comparability and investor protection measures. The widening of funding sources is also considered on a geographical aspect: the Capital Markets Union shall become more attractive for international investors and measures should be taken to reduce barriers for the marketing of EU investment vehicles in third countries.

• The EU Commission intends to improve market effectiveness. In this respect, the ESAs will be given

greater powers and play a central role to improve convergence. Further, obstacles to market effectiveness should be overcome by undertaking harmonisation work notably with regard to collateral management, taxation, protection of investors’ right, improvement of governance rules through stronger protection of minority shareholders, reduction of divergences between national insolvency regimes, alignment of company law rules to technological evolutions (“FinTech”).

The deadline to submit views is 13 May 2015.

As part of the consultation paper, the Commission also highlights its priorities for the coming months, where it will undertake work on:

• proposals to encourage high quality securitisation and free up bank balance sheets to lend

• the review of the Prospectus Directive

• improved access to finance for SMEs and making credit information on SMEs easier to access for investors

• collaborate with the industry for the creation of a European private placement regime

• support the take up of ELTIFs

The Green Paper is available at the following link.

http://ec.europa.eu/finance/consulta-tions/2015/capital-markets-union/docs/green-paper_en.pdf

EC Consultation Document: “An EU framework for simple, transparent and standardized securitization”

On 18 February 2015 the EC issued a Consultation Document titled “An EU framework for simple, transparent and standardized securitization” with the aim to gather information from the stakeholders on the current functioning of the European securitisation market and eventually improve the EU legal framework.

The document is divided into two sections: the first part provides information on the background and the initiatives already taken at EU and international level on the securitization market, the second part deals with the identification criteria for qualifying securitization market and the questionnaires for the stakeholders. Comments on the views reflected in the Consultation Document are expected by 13 May 2015 at the latest.

Background

In November 2014, Junker presented his Investment Plan for Europe, identifying “securitization” as one of the five areas for a short term intervention. Besides, in its “2015 work programme” the Commission announced the development of a framework for a high-quality securitization market, in order to build a harmonized Capital Markets Union and contribute to the main EU priorities of a sustainable growth and job creation.

Securitisation is a process through which the issuer, typically a bank, combines a set of loans or assets (e.g. mortgages, auto leases, consumer loans, credit cards) by converting them into securities. The issuer creates a

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pool of assets and repackages a portfolio of its loans with different risk categories in order to be risk appetite for investors. Returns to investors are generated from the cash flows of the underlying loans. The whole process aims to increase liquidity in the marketplace.

At European and international level, a number of initiatives have been already put in place with the objective to improve the framework for EU securitization and boost the slow recovery of the securitization market following the financial crisis. In May 2014, the European Central Bank (ECB) and the Bank of England (BoE) issued a joint paper on “The case for a better functioning securitization market in the European Union”, offering some food for thought. In addition, the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commission (IOSCO) are jointly leading a cross-sectorial Task Force on the impediments to securitization.

Qualifying securitization market in EU

The current EU legal framework for securitization is determined by a large number of legislative acts, in particular the Capital Requirements Regulation for banks, the Solvency II for insurers and UCITS and AIFMD for asset managers. In spite of the existence of an extended regulatory framework, the EU institutions registered a lack of a safe and robust securitization market enable to attract a wide range of investors and better allocate financial resources.

In order to develop a qualifying securitization market, the Commission

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is working on a framework with the aim to:

• create an effective funding channel to the economy;

• produce an efficient risk transfers available for different type of investors;

• make securitisation available for nonbanks as well as banks;

• better protect investors and manage the systemic risk.

Already in 2014, the EC introduced a differentiated approach for a more risk-sensitive treatment of securitisations in the EU, setting up a group of eligibility criteria in line with the principles of simplicity, transparency and comparability (“standardized”). These elements are relevant across the whole financial system and form the foundation criteria. These criteria are then supplemented by a range of additional criteria based on specific risks and for specific prudential requirements in a given sector.

As result of Solvency II and Liquidity Coverage Ratio Delegated Acts, the eligibility criteria were distinguished in 4 categories:

1. Simplicity criteria: homogeneity requirements for the underlying (i.e. no mixed pool of asset types), use of derivatives restricted to hedging and exclusion of re-securitisation.

2. Transparency criteria: transparency and disclosure requirements, such as the provision of loan-level data.

3. Standardisation criteria: no synthetic securitization and robust

transfer of the underlying exposures from a legal point of view (e.g. there is a “true sale”).

4. Additional risk features: provisions requiring the assessment of the creditworthiness of the borrowers is assessed thoroughly, in accordance with the Mortgage Credit Directive (Directive 2014/17/EU) or the Consumer Credit Directive (Directive 2008/48/EC), minimum levels of credit quality and seniority of the tranches. For the Liquidity Coverage Ratio and metrics of liquidity. The instruments should also be listed on a regulated market or recognised exchange, or be admitted to trading on another organised venue, with robust market infrastructure.

The abovementioned criteria however only apply to banks and insurers and it is therefore necessary to broaden the scope of application. For the foundation criteria, the objective is to identify instruments in which the underlying risks are appropriately disclosed and where it is easy to understand what assets are included and how they are packaged.

In the above context, the questionnaire refers to the identification of foundation criteria and further specific criteria for qualifying securitisation. It also goes on the additional considerations of information to be disclosed to investors and implementing measures. Moreover, questions are raised on the prudential treatment for banks and non-banks, as well as on the regulatory frameworks applicable to other institutional investors. The last part of the questionnaire deals with the role and the impact of securitization for SMEs.

Fund News / Issue 123 / Developments in January 2015 / 5

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The consultation paper is available at the following link.

http://ec.europa.eu/finance/consul-tations/2015/securitisation/docs/consultation-document_en.pdf

Council agrees on final rules regarding indices used as Benchmarks

On 13 February 2015, the European Council agreed on a final position regarding the proposal for a Regulation on indices used as benchmarks in financial instruments and financial contracts.

The European Commission published its proposal on benchmarks in November 2013. The draft text agreed by the Council introduced the following main changes:

1. Scope:

• The Council agreement maintains in the scope of the regulation, all published indices used to reference the price of or the amount payable under a financial instrument or contract. However, more details are provided concerning benchmarks that are used by investment funds specifying that the scope includes the indices used with the purpose to track their return, to define the asset allocation of a portfolio or to compute the performance fees.

• IORPs, creditors as defined in Consumer Credit Agreement Directive, non-credit institutions as defined in the mortgage credit directive and market operators as

defined in MiFIR are now also considered as supervised entities.

• Regulated-data benchmarks are introduced in the Council agreement. Those refer to a benchmark determined by the application of a formula either from input data contributed entirely and directly from trading venues, APA (approved publication mechanism, ARM (approved reporting mechanism), an auction platform or electricity or natural gas exchange; or either NAV of UCITS.

• Critical benchmarks are now defined as benchmarks that are not a regulated-data benchmark and whose cessation would impact the financial stability of the market.

2. Family of benchmarks and specific Benchmark requirements:

• Some rules will be applicable by family of benchmarks, that is a group of benchmarks provided by the same administrator. For instance, a single code of conduct may be adopted for the same family of benchmarks.

• Requirements are divided between general requirements and specific requirements for different types of benchmarks and sectors. For this purpose, specific requirements shall apply to interest-rate benchmarks, critical benchmarks and commodity benchmarks in addition or substitution to the general requirements. As for regulated-data benchmarks, specific reduced requirements will be applicable.

• The commission will adopt a list of critical benchmarks containing

benchmarks in accordance with the new definition and also meet one of the following conditions:

– Threshold of 500 billion euros on the basis of maturities or tenors of the benchmarks

– Benchmarks in which supervised entities contribute that have a value between 400 and 500 billion euros, with very few substitutes, and that will have a significant impact on the market in case of cessation, are considered as critical.

3. Third-country provision:

• A process of prior recognition of administrators located in a third country by the competent authority of the Member State of reference

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is introduced under certain conditions. More particularly, the administrator must have a legal representative established in its Member State of Reference, to be determined following objective rules detailed in the text. The recognition process can be requested by third country administrators that are supervised by a third country authority entering into an appropriate cooperation agreement with the competent authority of the Member State of reference.

• A mechanism is also proposed to allow EU administrators of benchmarks to endorse a benchmark provided in a third country, under conditions, for a period of five years after the entry into force of the regulation.

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4. Next steps

The vote on the report of the Parliament, necessary to start the negotiations between the institutions to seek a compromise on the final text and initially intended to take place in March, has just been rescheduled and may now not happen before the autumn. This will counteract the Council intention to see the Latvian presidency start the negotiations swiftly.

The agreement of the European Council on a final position regarding the proposal for a Regulation on indices used as benchmarks in financial instruments and financial contracts is available at the following web link.

http://data.consilium.europa.eu/doc/document/ST-5921-2015-INIT/en/pdf

Anti-money laundering: the EU Council approves the agreement with the European Parliament

On 10 February 2015, the Council endorsed the agreement with the EP on the rules to prevent money laundering and terrorist financing and for the information accompanying transfer of funds. The legislative package, which includes a directive and a regulation, aims to strengthen the European provisions and ensure a consistency with the measures adopted at international level. Both texts, indeed, implement the recommendations issued by the Financial Action Task Force (FATF). Additional or extended rules are also included to take account of the new methods used by criminals, such as extension of the scope to a greater number of traders, use of evidenced-

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ESMA publishes peer review on best execution supervisory practices under MiFID

On 25 February 2015, ESMA issued a “peer review report” (ESMA/2015/495) examining how EU securities regulators supervise and enforce the requirement under MiFID to provide best execution, or obtain the best possible result when executing client’s orders. The review, covering the situation between January 2011 and December 2012 across 29 jurisdictions and complemented by on-site visits in the course of 2014 in 6 jurisdictions, compared the application of the guidelines and the supervisory practices in those jurisdictions. ESMA’s review highlighted that the level of convergence of supervisory practices is relatively low.

Key findings of the report are:

• Oversight of best execution is often limited to ensuring that a best execution policy is in place but does not challenge the way firms assess the quality of the best execution.

• Cost, speed, likelihood of execution and settlement and order size are not sufficiently included in the assessment of best execution.

• There is a lack of monitoring of the best execution for non-equity and less liquid markets.

• There is a limited number of alternative venues.

As a result ESMA emphasizes the need of convergence in supervisory and enforcement practices regarding best execution and identifies actions

that may be initiated together with the National Competent Authorities, including:

• Develop guidance to help convergence in the understanding of the best execution rules,

• Review the adequacy of the resources of the National Competent Authorities dedicated to the monitoring of best execution,

• Identify the obstacles to the development of alternative trading venues,

• Develop in coordination with the National Competent Authorities assessment criteria applicable in the context of single trading venues.

The full report is available via the following web link.

http://www.esma.europa.eu/system/files/2015-494_peer_review_report_on_best_execution_under_mifid.pdf

ESMA puts FX Non-Deliverable forward classes out of scope for central clearing under EMIR

On 04 February 2015, the European Securities and Markets Authority (ESMA) announced that it will not consider the proposed 11 classes of foreign exchange non-deliverable forwards (FX NDF) for central clearing via a central counterparty (CCP) under the European Markets Infrastructure Regulation (EMIR).

The consultation paper in October 2014 on the clearing obligation for FX

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based decision making to better target risks and application of enhanced or simplified measure to the customer due diligence depending on the risk assessment.

Information on beneficial ownership will be stored in a central register. Such register will be accessible, without restriction, to competent authorities, financial intelligence units and other “obliged entities” conducting “know your customer” (KYC) checks. Access will also be granted to any person or organization that can demonstrate a “legitimate interest” to access information regarding in particular, the beneficial owner’s name, month and year of birth, nationality, residency and other details.

The final text introduces a maximum pecuniary fine of at least twice the amount of the benefit derived from any breach or at least €1 million. Whenever the breach involves credit or financial institutions, the penalty will amount to a maximum of at least €5 million or 10% of the total annual turnover in the case of a legal person and a maximum of at least €5 million in the case of a natural person.

The legislative package has now to be voted by the EP at second reading. After this, it will be published in the EU Official Journal and Member States will have two years to transpose the directive into national law. The regulation will be directly applicable.

The text of the agreement is available at the following web link.

http://register.consilium.europa.eu/doc/srv?l=EN&f=ST 5748 2015 INIT

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NDF resulted from the authorization of LCH.Clearnet Ltd (UK) on 12 June 2014. At the time of its authorization, the CCP was already clearing 11 classes of FX NDF, which under EMIR forces ESMA to consider those for mandatory central clearing. In fact, the European markets regulator proposed at the time to include the approximately 2.7% of the daily turnover on the FX OTC derivative market in Europe (based on trade repository data) in the scope of central clearing. However, ESMA reviewed its proposal after considering industry input. A few of the many industry’s concerns raised with ESMA are summarized below:

• The clearing offer for FX NDF is still in its infancy stage and market infrastructures have little experience (e.g. with price disruptions) with clearing this asset class.

• While the contracts cleared via LCH.Clearnet Ltd are relatively standardized, other non-recognized CCPs also offer clearing of non-standardized contracts, which are less liquid and automated than other asset classes (i.e. IRS, CDS).

• Only one European CCP is currently authorized to clear FX NDF , which might result in major operational constraints in terms of onboarding and competition and also, none of the third country CCPs clearing FX NDF is yet recognized

• The definition of FX derivatives is not consistent across Europe.

• International convergence of a clearing mandate and synchronization in the application date for FX NDF is lacking, which

might lead to fragmentation in the FX NDF market.

• Lack of client clearing services at CCPs and lack of clearing members for buy-side firms.

In light of the concerns raised in the responses to the consultation, ESMA will take the time to address them appropriately and will not require mandatory clearing for the 11 proposed classes of FX NDF at this stage. However, ESMA may include FX NDF to the clearing obligation in the future, taking into account further market changes.

The complete feedback statement (2015/ESMA/234) is available under the following link

http://www.esma.europa.eu/system/files/2015-esma-234_-_feedback_statement_on_the_clearing_obliga-tion_of_non_deliverable_forward.pdf

ESMA issues its technical advice to the European Commission on Market Abuse Regulation (MAR)

ESMA published on 04 February 2015 its technical advice regarding the new Market Abuse Regulation. This final report follows the Consultation Paper published by ESMA on 15 July 2014, and is divided into five main sections:

• specification of the indicators of market manipulation;

• minimum thresholds for the purpose of the exemption for certain participants in the emission allowance market from the

requirement to publicly disclose inside information;

• determination of the competent authority for notification of delays in public disclosure of inside information;

• type of managers’ transactions to be reported and issuer’s transactions permitted during a closed period; and

• reporting of infringements.

This paper also contains, for each question originally included in the Consultation Paper, the summary of the market participants’ responses, as well as ESMA’s own comments to the responses received. In some cases, the proposed approach and the technical advice have been modified in order to reflect the suggestions provided by the respondents.

The technical advice:

• specifies the MAR market manipulation indicators by way of non-exhaustive examples of practices;

• recommends the minimum thresholds of carbon dioxide equivalent (CO2eq) and of rated thermal input to be set for the purpose of the exemption for certain market participants in the emission allowance market from publicly disclosing inside information;

• suggests the way to determine to which regulator delays in disclosure of inside information needs to be notified should the issuer be located in a Member State or in a Third Country;

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• provides clarifications on the enhanced disclosure of managers’ transactions. ESMA recommends disclosing any acquisition, disposal, subscription or exchange of shares or debt instruments of the relevant issuer or of related derivatives or other financial instruments linked to them, or of emission allowances or related auction products or derivatives, further illustrated with a non-exhaustive list of types of transactions subject to this obligation. ESMA also clarifies the conditions under which a person discharging managerial functions within an issuer may enter into transactions during a closed period; and

• proposes procedures and arrangements to ensure sound whistleblowing infrastructures.

Next Steps

The delegated acts should be adopted by the Commission so that they enter into force for the 2 July 2016 at the latest, taking into account the right of the European Parliament and Council to object to a delegated act within 3 months (which can be extended by a further 3-month period). ESMA’s regulatory technical standards

regarding MAR will be delivered in July 2015.

The text of the technical advice on MAR is available at the following web link.

http://www.esma.europa.eu/system/files/2015-224.pdf

ESMA issues its Technical Advice to the European Commission on delegated acts of EuSEF and EuVECA Regulations

On 3 February 2015, the European Securities and Markets Authority (ESMA) published its “Technical Advice to the European Commission on the delegated acts of the Regulations on European Social Entrepreneurship Funds (EuSEF) and European Venture Capital Funds (EuVECA).

The Commission requested the ESMA advice for the preparation of the delegated acts on 27 May 2014, with an expected delivery deadline by the end of April 2015. The ESMA Advice takes into account the work carried out by the Commission’s expert group on social business (GECES) as well as the

views expressed by stakeholders during the ESMA public consultation that ran from 26 September until 10 December 2014 (refer to the Issue 119 _September Fund News),

http://www.kpmg.com/LU/en/Issue-sAndInsights/Articlespublications/Pages/FundNews-Issue119-Septem-ber2014.aspx

the open hearing with experts organised by ESMA on 10 November 2014 and the opinion of the Securities and Markets Stakeholder Group of ESMA.

The Report is divided in five parts. The first deals with the advice on the types of goods and services embodying a social objective in EuSEF. The second and third parts deal with the advice on the conflicts of interest of EuSEF and EuVECA managers, respectively. The fourth part deals with the advice on the methods for the measurement of the social impact. The fifth part deals with the advice on the information to be provided to investors in a EuSEF.

In particular, the technical advice:

1. Specifies the type of goods and services, the methods of production for goods and services and the financial support embodying the social objectives of the EuSEF qualifying portfolio undertakings. In particular, according to the definition of “social enterprises” provided by GECES report, the primary purpose of an enterprise in which the EuSEF shall invest, must be addressing a social and/or environmental problem and the enterprise must use its profits primarily to achieve its social objective. The goods or services

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produced by those enterprises shall be primarily addressed to those persons that are in situation of exclusion, disadvantage or marginalization and are considered as “vulnerable”. ESMA however provides a non-exhaustive list of circumstances where the enterprise may be a qualifying portfolio undertaking although the goods and services produced are not necessarily addressed to vulnerable persons. The EuSEF manager shall be in charge to assess case by case the compliance with the above requirements. To be noted that the advice clarifies that having a positive social or environmental impact, including a Corporate Social Responsibility plan is not sufficient to become a qualifying portfolio undertaking.

2. Provides guidance on how managers of EuSEF and EuVECA shall identify the types of conflicts of interest and the procedure to be followed to prevent, manage, monitor and disclose them. In particular both managers shall establish a written “conflicts of interest” policy, which is appropriate to the size and organisation as well as to the nature, scale and complexity of their business. The policy shall identify the circumstances that may give raise to a conflict of interest and indicate the procedures and measures in order to prevent, manage and monitor such conflicts on an ongoing basis. These measures shall include: preventing the exchange of information between relevant persons where needed; separating the supervision of relevant persons whose interest may conflict; removing links in the

remuneration of relevant persons engaged in different activities where a conflict may arise; avoiding inappropriate influence over the management by relevant person. Where the abovementioned measures are not sufficient, the senior management shall take the necessary actions to ensure the protection of the investors’ best interest. In addition to the previous requirements, the EuVECA manager must develop strategies in relation to the exercise of voting rights and must provide information to investors on those strategies and the actions taken on their basis.

3. Details the procedures required in order to measure the extent to which the qualifying portfolio undertakings achieve their committed social impact. The EuSEF manager shall use a methodology in line with the size and the complexity of the business, taking into consideration the qualifying portfolio undertakings, the target beneficiaries, the stakeholders and a set of indicators. The measurement shall be performed by the manager or by third parties, including the qualified portfolio undertakings themselves. The relevant stakeholders shall be involved in the measurement process, by agreeing with the qualifying portfolio undertaking the measures to be applied. The results of the assessment shall be disclosed to investors in a clear and transparent manner.

4. Enhances the process to disclose information to investors prior to taking an investment decision. In particular, the EuSEF manager shall provide to investors information

regarding the types of qualifying portfolio undertakings; the social sector where the qualifying portfolio undertakings are active; the geographical area where the activities take place; the sector of the society to which the activities are addressed; the legal form of the target companies. Additional information on the type of assets, the investment techniques and any applicable investment restrictions shall be provided by the manager as well. With regard to the investment techniques, the EuSEF manager shall inform the investors on the nature of the eligible assets, in particular whether he intends to use equity instruments, quasi-equity instruments, securitised or unsecuritised debt instruments, secured or unsecured loans or any other type of participation in the qualifying portfolio. The information shall be presented in a clear and understandable manner and additional documents/information need to be provided such as the targeted social impact, its related recorded performance and a copy of the last annual report or a summary of the relevant information reported in the annual report.

ESMA will now provide input to the Commission as necessary on the development of the delegated acts to be prepared on the basis of ESMA’s technical advice.

The ESMA technical advice is available at the following link.

http://www.esma.europa.eu/system/files/2015-esma-227_-_final_report_on_advice_on_eusef-euveca.pdf

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Wholesale Sector Competition Review

Wholesale financial markets play a crucial role in the economy and it is important that they are not only clean but also competitive.

In July 2014, the FCA launched a review of competition in the wholesale sector to gather views on areas that might benefit from further investigation through an in-depth market study. Based on the FCA’s analysis of the market and the feedback received, the FCA will be undertaking a market study to investigate competition in the investment and corporate banking sector. The FCA will consider undertaking a market study at asset management and related services later in the year. This would focus on how purchasers got value for money when buying asset management and related services.

This feedback statement:

• Explains why the FCA has chosen this topic for their first wholesale market study

• Sets out timescales and next steps

• Summaries the wider responses the FCA received to the call for inputs and the FCA’s view on conducting further market studies on the issues raised.

The summary of the feedback noted some features of the purchase and provision of asset management and related services may mean competition is not working effectively in the market:

• Investors may not be able to assess effectively whether they are

UK

getting value for money for asset management and investment consulting services

• Asset managers may not have sufficient incentives or ability to control costs incurred on behalf of investors along the asset management value chain

• The bundling of some ancillary services may impact the way competition works for these services.

This consultation paper is aimed at individuals and organisations who are interested in how competition in wholesale markets can generate good outcomes for consumers, firms and the market. These include wholesale market participants, consumers and trade associations.

The FCA will publish a terms of reference, which will set out the scope of the market study and signal its launch, in Spring 2015.

A link to the consultation can be found here.

http://www.fca.org.uk/static/docu-ments/feedback-statements/fs15-02.pdf

Dealing Commission Feedback Statement

Dealing commissions are the charges paid by consumers when investment managers execute trades and acquire external research on their behalf.

In July 2014, the FCA published a discussion paper that detailed their

thematic work and policy analysis on the dealing commission regime. The FCA noted that there was no substantive new evidence submitted to them. The FCA maintain their view that the benefits of reform would outweigh the potential negative impacts. The FCA therefore support ESMA’s final advice which proposes restrictions on inducements for portfolio managers. This prevents them from receiving more valuable research linked to their execution arrangements with brokers and transaction costs passed to customers. Any changes to FCA domestic rules on the use of dealing commission (COBS 11.6) will be in line with the final reforms under MiFID II.

This feedback statement:

• Forms part of our broader focus on wholesale conduct

• Summarises responses received to the FCA competition and policy analysis of potential reforms to their current dealing commission regime linked to proposals under MiFID II

• Sets out the FCA’s views on further developments in EU discussions and next steps.

The feedback statement is aimed at:

• Investment managers, including UCITS management companies when carrying on scheme management activity and alternative investment fund managers (AIFMs) carrying out AIFM investment management functions respectively.

• Customers of investment managers, including:

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– institutional investors, for example retail fund and pension fund trustees

– retail investors who have investments in retail funds (which may be through a wrapper such as an Individual Savings Account), or who have a direct relationship with an investment manager, for example individuals with discretionary-managed investment portfolios

• Brokers (including investment banks), and third-party providers of independent research and other ancillary services supplied to investment managers

• Corporate issuers

• Relevant trade associations and representative bodies for the above groups.

The FCA will publish further information, including a consultation on our overall implementation of MiFID II, by late Q4 2015.

A link to the feedback statement can be found here.

http://www.fca.org.uk/static/docu-ments/feedback-statements/fs15-01.pdf

Market Abuse Controls

Market abuse damages market integrity and undermines confidence in financial markets. At a firm level, association with market abuse causes reputational damage and can lead to

substantial financial loss. The FCA’s regime requires firms to have effective processes to identify, monitor and manage the risk of market abuse.

The FCA published their thematic review looking at asset management firms and the risks of market abuse. The review considered how firms control the risks of insider dealing, improper disclosure and market manipulation, with a primary focus on equities and insider dealing.

FCA Findings

The FCA found that asset managers had out in place some practices and procedures to control the risk of market abuse, but these were only comprehensive in a small number of firms.

In many firms further work is required to ensure procedures operate effectively and cover all material risks. In particular, firms need to pay more attention to the possibility of receiving inside information through all aspects of the investment process and take steps to manage this risk. Firms generally also need to improve the effectiveness of post-trade surveillance. Only a minority of firms had appropriate controls for these matters. The report contains examples of good and poor practice that firms may find useful.

This review is aimed at asset management firms and trade bodies representing asset management firms.

The FCA will shortly be writing to all the firms in their thematic sample to provide individual feedback. Where firms did not effectively manage the risk of market abuse, the FCA will

expect them to make improvements to their practices.

Senior management of asset management firms need to satisfy themselves that their firm’s practices to manage the risk of market abuse are appropriate. The FCA will follow up on this through their routine supervision.

The thematic review can be found here.

http://www.fca.org.uk/static/docu-ments/thematic-reviews/tr15-01.pdf

FCA fines Aviva Investors £17.6m for systems and controls failings that led to its failure to manage conflicts of interest fairly

On the 24 February 2015, the FCA announced that it had fined Aviva Investors Global Services Limited (Aviva Investors) £17,607,000 for systems and controls failings that meant it failed to manage conflicts of interest fairly. Aviva Investors breached Principle 3 (Management and control) and Principle 8 (Conflicts of interest) of the Authority’s Principles for Businesses and related Rules. These weaknesses led to compensation of £132,000,000 being paid to ensure that none of the funds Aviva Investors managed was adversely impacted. On issuing the announcement, the FCA stated:

“Ensuring that conflicts of interest are properly managed is central to the relationship of trust that must exist between asset managers and their customers. It is also a fundamental regulatory requirement. This case serves as an important reminder to firms of the importance of managing

Regulatory News

Fund News / Issue 124 / Developments in February 2015 / 13

conflicts of interest effectively by implementing a robust control environment with effective systems to manage the risks. Not doing so risks customers’ interests being overlooked in favour of commercial or personal interests…”

The FCA’s final notice on this matter can be found here.

http://www.fca.org.uk/static/docu-ments/final-notices/aviva-investors.pdf

Whistleblowing in deposit-takers, PRA-designated investment firms and insurers

The Parliamentary Commission on Banking Standards recommended that banks put in place mechanisms to allow their employees to raise concerns internally, and that the FCA and the PRA ensure these mechanisms are effective.

The FCA, with the PRA, have in response proposed a package of measures to formalise firms’ whistleblowing procedures. These proposals aim to move towards a more consistent approach, building on existing good practice in firms. They aim to ensure that all employees are encouraged to blow the whistle where they suspect misconduct, confident that their concerns will be considered and that there will be no personal repercussions.

The FCA and PRA propose that relevant firms should:

• Put internal whistleblowing arrangements in place (if they are

not already), and inform their UK-based employees about these arrangements

• Inform their UK-based employees that they can blow the whistle to the FCA or PRA

• Offer protection to all whistleblowers whatever their relationship with the firm and whatever the topic of their disclosure

• Include a passage in new employment contracts and settlement agreements clarifying that nothing in that agreement prevents an employee, or ex-employee, from making a protected disclosure

• Allocate the prescribed responsibility for whistleblowing under Senior Managers Regime and Senior Insurance Managers Regime to an individual (referred to as the “whistleblowers’ champion”) with responsibility for:

– Overseeing the effectiveness of internal whistleblowing arrangements, including arrangements for protecting whistleblowers against detrimental treatment

– Preparing an annual report to the board about their operation

– Reporting to the FCA where, in the case before an employment tribunal contested by the firm, the tribunal finds in favour of the whistleblower.

This consultation paper proposes a set of rules that will apply to UK banks,

building societies, credit unions, PRA-designated investment firms and insurance and reinsurance firms, including third country branch undertakings, within the scope of Solvency II, and to the Society of Lloyd’s and managing agents. The FCA and PRA propose that the requirements are not imposed on small credit unions with £25m or less in assets.

The consultation closes on the 22 May 2015 and the associated Paper can be found here.

http://www.fca.org.uk/static/docu-ments/consultation-papers/cp15-04.pdf

UK Listing Authority fees: covering the cost of regulation

The FCA is considering options on how they should recover the costs they incur when carrying out their duties as the UK Listing Authority (UKLA) overseeing the listing, transparency and prospectus regimes.

This discussion paper affects any:

• Company that has its securities listed on the Official List or who may apply for listing of securities in the future

• Person who is required to publish an approved prospectus or who may be required to do so in the future

• Company that has been approved by the FCA to act as a sponsor advising premium listed companies on their obligations under the listing regime, or that might seek approval in the future

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14 / Fund News / Issue 124 / Developments in February 2015

• Primary information provider that distributes regulated information on behalf of issuers, or might consider doing so in the future

• Person or company who is considering, or may in the future consider, undertaking or advising on transactions or documents that require UKLA approval.

The FCA intends to set out proposals in their paper on fees that they will publish in October 2015 as part of their normal fees consultation cycle, so that they can introduce any revised charging structure from 1 April 2016.

The closing date to respond to this discussion paper is 20 April 2015 and a copy of the paper is available here.

http://www.fca.org.uk/static/fca/documents/discussion-papers/dp15-1 ukla-covering-the-cost-of-regula-tion18022015.pdf

Version 3.1 of the Transaction Reporting User Pack

In May 2014, the FCA consulted on changes to the guidance for transaction reporting set out in the Transaction Reporting User Pack (TRUP).

TRUP provides guidance to firms on understanding the transaction reporting obligations that come from Directive 2004/39/EC on MiFID, implemented through SUP17 of the FCA Handbook.

Version three of the TRUP was published in March 2012 following a consultation of the entire text.

In response to some queries from firms and some ongoing transaction reporting issues the FCA sought to clarify existing guidance, proposed some changes to the text, and corrected some minor errors.

What the FCA clarified?

The areas the FCA sought to clarify were:

• That the transaction reports a firm sends for its transactions must accurately reflect the change in position for the firm and its client(s) resulting from the transactions

• That a firm hitting its own order on a trading venue should transaction report the resultant transaction

• How the unit price should be reported for different instruments

• How to report the venue for a transaction

• What the FCA expected for transaction reporting arrangements within firms.

Response to feedback received

The FCA considered the responses and publishing finalised guidance, along

with a summary of the feedback received. In some cases the FCA have provided additional clarification and examples.

Version 3.1 of the TRUP will be effective immediately, with the exception of the guidance introduced in sections 7.5. Trading capacity, 7.18.2 Use of “INTERNAL” and 9.1 Internal transactions, which will be effective from 6 August 2015.

For TRUP Version 3.1 finalised guidance click here.

http://www.fca.org.uk/static/docu-ments/finalised-guidance/fg15-03.pdf

For changes made to the text consulted on click here.

http://www.fca.org.uk/static/docu-ments/finalised-guidance/fg15-03-changes.pdf

For summary of feedback received click here.

http://www.fca.org.uk/static/docu-ments/finalised-guidance/fg15-03-feedback.pdf

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Fund News / Issue 124 / Developments in February 2015 / 15

• Risk Management in UCITS – Examination of the on-going application of risk management processes employed by UCITS.

• Integrity of Regulatory Returns – Review of firms’ regulatory reporting.

See the following link for further details.

http://www.centralbank.ie/press-area/press-releases/Pages/Central-Bankpublishesprogrammeoftheme-dinspectionsinMarketsSupervision.aspx

CBI Enforcement Priorities 2015

On 9 February the Central Bank published its statement of enforcement priorities for 2015. Enforcement priority areas include:

• Prudential requirements;

• Systems and controls;

• Provision of timely, complete and accurate information to the Central Bank;

• Appropriate governance and oversight of outsourced activities;

• Anti-Money Laundering / Counter Terrorism Financing compliance; and

• Fitness and probity obligations.

ICAV Bill Passed

On 20 February the Irish Collective Asset-management Vehicle (“ICAV”) bill was passed by both houses of the Irish parliament. The ICAV is a new form of corporate vehicle specifically tailored for funds which may elect under the US “check the box” rules to be treated as a “pass through” entity for US federal income tax purposes.

The next steps are for the Prime Minister to send the Bill to the President for signing and enactment and finally for the Minister for Finance to sign a commencement order.

For further information on the ICAV see KPMG’s publication at the following link.

https://www.kpmg.com/ie/en/issue-sandinsights/articlespublications/documents/fs-icav-flyer-feb-2015.pdf

CBI Themed Inspections 2015

On 26 February the Central Bank published its programme of themed-inspections in Markets Supervision. Those in the funds industry should, in particular, be aware that the Central Bank’s focus will include:

• Treatment of Pricing Errors for the Calculation of Fund NAVs – Examination of the processes for the treatment of pricing errors and the payment of compensation.

• Depositary Oversight – Review of depositary oversight of investment funds including the depositary’s annual report to investors.

Ireland

Enforcement activity will not be confined to the areas set out above. See the following link for further details.

http://www.centralbank.ie/press-area/press-releases/Pages/Central-Bankpublishesenforcementpriori-tiesfor2015.aspx

CBI – Fitness and Probity FAQ

Further to our report in Fund News January 2015 on the Central Bank’s service standards report on its “Fitness and Probity Regime”, on 18 February 2015 the Central Bank published FAQ on its “Fitness and Probity Regime” available at the following link.

http://www.centralbank.ie/regula-tion/processes/fandp/serviceprovid-ers/Documents/Final%20FAQ%20-%20February%202015.pdf

CBI Report on AML

On 17 February the Central Bank reported on its observations on AML/CTF compliance by banks in Ireland.

While the banking sector in Ireland is the specific focus of the Report, many of the issues raised are relevant to the broader financial services sector in Ireland. The Central Bank has stated that it expects all financial and credit institutions to carefully consider the

Regulatory News

16 / Fund News / Issue 124 / Developments in February 2015

Switzerland: FINMA launches consultation on FINMA Anti-Money Laundering Ordinance

On 11 February 2015, the Swiss Financial Market Supervisory Authority (FINMA) has initiated the consultation on the draft of the revised the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA). The draft of the AMLO-FINMA implements the revised Financial Action Task Force recommendations of 2012 and the latest amendment to the Anti-Money Laundering Act (AMLA) in December 2014. The consultation phase will run until 7 April 2015.

The AMLO-FINMA in its current form has been in force since 1 January 2011. The revised AMLA was passed by the Swiss parliament in December 2014, reflecting the partially revised recommendations on internationally recognised standards on combating money laundering and the financing of terrorism. Therefore, the AMLO-FINMA needs to be adapted to these new regulation as well.

The draft AMLO-FINMA sets forth a new title, “Special Provisions for Fund

Switzerland

issues raised in the report, and to use the report to inform the development of AML/CFT frameworks.

The report is available at the following link.

http://www.centralbank.ie/regula-tion/processes/anti-money-laun-dering/Documents/Report on Anti Money Laundering.pdf

Speech by CBI’s Director of Markets Supervision

On 26 February Gareth Murphy, the Central Bank’s Director of Markets Supervision delivered a speech to the 4th Annual Funds Congress addressing a number of topics, including:

• The Central Bank’s proposed roll out of a electronic funds authorisation platform;

• The Central Bank’s themed inspections for 2015;

• Feedback to the Central Bank’s consultation on fund management company effectiveness & delegate oversight;

• ESMA’s work on AIFMD’s Third Country Passport and National Private Placement Regimes; and

• ESMA’s work on UCITS V Remuneration Guidelines.

Management Companies, Collective Investment Scheme (CIS)-Investment Companies and CIS-Asset Managers”. Key points of these new provisions (art. 39 et seq. revised AMLO-FINMA) are the following:

Fund management companies and CIS-investment companies

• Duty to identify the subscribers, controllers and/or beneficial owners of Swiss collective investment schemes not listed on a stock exchange, if the subscription exceeds the amount of CHF 15,000;

• Exemption of this duty if the subscriber is a bank or a securities dealer subject to an adequate supervision ;

• In case that a fund management company, a SICAV or a SICAF choses to delegate its duties of due diligence and documentation to a custodian bank, there will be a facilitation of the duty to identify. The delegating person remains responsible for complying with these duties from a supervision point of view.

Fund News / Issue 124 / Developments in February 2015 / 17

CSSF publishes description of controls performed on submitted AIFMD reporting files

On 11 February 2015, the Commission de Surveillance du Secteur Financier (CSSF) released a first version of a document aimed at Luxembourg AIFMs and technical agents and providing information on the treatment of an AIFMD reporting file, including the controls performed, and describing the feedback files that are returned by the CSSF.

Should the AIFM or the technical agent encounter problems with feedback files and/or error messages, they shall report these issues to their service provider and/or contact the CSSF.

According to the CSSF, every AIFM and technical agent must receive at least three positive feedback files until all control checks are performed adequately. However, this does not mean that the CSSF may not request more information about the reporting file(s) at a later stage.

The CSSF intends to keep this document up-to-date to take into considerations any problems encountered with the submission of AIFMD reporting files.

The document is available under the following link.

http://www.cssf.lu/fileadmin/files/AIFM/CSSF_ERROR_CODES_FEED-BACK_FILES_V_2_0.pdf

Luxembourg

Asset manager of foreign collective investment schemes

• Duty to identify subscribers, controllers and/or beneficial owners of foreign collective investment schemes that are not listed on a stock exchange, if

i neither the foreign collective investment scheme nor its management company are subject to an appropriate regulation of combating money laundering and the funding of terrorist activities;

ii the asset manager does not proof, that the appropriate regulation of combating money laundering and the funding of terrorist activities, is applied by another financial intermediary (that is subject to an appropriate prudential supervision, e.g. custodian or broker of an offshore fund); and

iii the invested amount exceeds CHF 15,000.

• Exemption of this duty if the subscriber is a bank or a securities dealer subject to an adequate supervision and is subject to an appropriate regulation of combating money laundering and the funding of terrorist activities.

The methods regarding the identification of the contractual parties and the determination of controllers and beneficial owners follow the agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence (CDB 15, not yet in force).

IOSCO issues the Review of Financial Benchmarks Principles

On 25 February 2015, the International Organization of Securities Commission (IOSCO) published its Review of the Implementation of IOSCO’s Principles for Financial Benchmarks. The Review was carried out after the publication of the Final Report, which was released by IOSCO in July 2013 (refer to Fund News Issue 105, July 2013).

The Principles contained in the Final Report aimed to create a comprehensive framework of standards for Benchmarks used in financial markets. In particular, the principles were addressing:

• Governance: ensuring appropriate processes are in place to ensure integrity and to prevent conflicts of interest.

• Quality: promoting the quality and integrity of benchmarks through a set of requirements ensuring that the benchmark reflects a credible market in relation to the measurement it is used for.

• Methodology: requiring for a minimum of information to be addressed by the methodology and published.

• Accountability, establishing the process for compliance and audit revision that ensures compliance with the quality standards.

International

Regulatory News

18 / Fund News / Issue 124 / Developments in February 2015

In comparing the reviewed Benchmarks across the underlying asset classes, administrators of equity Benchmarks registered the highest level of compliance, with most of them having already published a statement of compliance. In several cases, external auditors had been appointed to certify the fairness of the statement. Administrators of fixed income and commodity Benchmarks revealed the highest reported levels of transition to new Administrators and under half stated that they were aligned with the Principles.

Concluding on the review, the Task Force acknowledges that additional work may be necessary in the future but that it is too early to clearly define the areas that will require further attention.

The Review of the implementation of IOSCO’s Principle for Financial Benchmarks is available here.

http://www.iosco.org/library/pub-docs/pdf/IOSCOPD474.pdf

The Final Report did foresee a revision process within 18-months of the publication in order to assess the extent of implementation of the principles, and understand what remains to be done.

The Review was conducted by a Review Team, established in October 2014 and made up of the staff from the UK Financial Conduct Authority (FCA) (Chair), the Financial Services Authority (Japan) (JFSA) and the Australian Securities and Investments Commission (ASIC). The revision process was realized through the submission of a questionnaire to a sample of 23 Administrators of 36 benchmarks across different asset classes and geographies and the examination of the statements of compliance published by them.

The result of the revision process showed a very high level of responses. In many cases, the administrations stated that they have used the principles in order to perform a gap analysis on their policies that would help them in the process of enhancement of the procedures. In addition, the majority of administrators have already taken steps to implement the Principles (all or in part), with many however reporting ongoing work. Most attention was directed towards improvement of the governance, but some administrators also changed their process for benchmark determination. Examples were also found of Administrators electing to wind-down individual or whole Benchmarks where the level of data was not sufficient for the Administrator to be satisfied that the Benchmark would be robust.

IOSCO issues the Review of Financial Benchmarks Principles

On 25 February 2015, the International Organization of Securities Commission (IOSCO) published its Review of the Implementation of IOSCO’s Principles for Financial Benchmarks. The Review was carried out after the publication of the Final Report, which was released by IOSCO in July 2013 (refer to Fund News Issue 105, July 2013).

The Principles contained in the Final Report aimed to create a comprehensive framework of standards for Benchmarks used in financial markets. In particular, the principles were addressing:

• Governance: ensuring appropriate processes are in place to ensure integrity and to prevent conflicts of interest.

• Quality: promoting the quality and integrity of benchmarks through a set of requirements ensuring that the benchmark reflects a credible market in relation to the measurement it is used for.

• Methodology: requiring for a minimum of information to be addressed by the methodology and published.

• Accountability, establishing the process for compliance and audit revision that ensures compliance with the quality standards.

International

Regulatory News

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Schweizerisches Recht der Kollektiven Kapitalanlagen

Swiss FinancialServices Newsletter: Special Edition Banking

EvolvingInvestmentManagementRegulation

Frontiers in Finance

KPeople 2010 | 03 01

SWISS FINANCIAL SERVICES

NEWSLETTER

Special Edition

Banking

July 2014

Swiss FinancialServices Newsletter: Special Edition Investment Management

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.

© 2015 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.

Zurich

Markus SchunkPartnerT: +41 58 249 36 82 E: markusschunk@kpmg.com

Christoph GroebliPartnerT: +41 58 249 29 76 E: cgroebli@kpmg.com

Geneva

Yvan MermodPartnerT: +41 58 249 37 80 E: ymermod@kpmg.com

Lugano

Lars SchlichtingPartner, LegalT: +41 58 249 32 59 E: lschlichting@kpmg.com

Astrid KellerPartnerT: +41 58 249 28 82 E: astridkeller@kpmg.com

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Pascal SprengerDirector, LegalT: +41 58 249 42 23 E: psprenger@kpmg.com

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Contacts

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