Loyens & Loeff

New CSSF practice for PRIIPs KID filings for Non-UCITS

On 11 April 2019, the Commission de Surveillance du Secteur Financier (the CSSF) has updated its Frequently Asked Questions concerning the Luxembourg Law of 12 July 2013 on alternative investment fund managers (the FAQ). In this update the CSSF confirms that the PRIIPs KIDs will only have to be filed with the CSSF upon request. The same applies where AIFs chose to issue a UCITS KIID like document instead of the PRIIPS KID. The FAQ per 11 April 2019 can be consulted here.

This update documents a change of the CSSF’s regulatory practice. The previous version of the FAQ had still foreseen that the CSSF requires the notification of a final PRIIPs KID by (the manufacturer of) a Luxembourg AIF.

Like in the past, this element of the FAQ is also relevant for SIFs and SICARs that are no AIF. This follows from the CSSF’s FAQ concerning SIFs and SICARs that do not qualify as AIFs.

Please contact the authors of this newsflash for more information or your regular Loyens & Loeff adviser.