The main objectives of this ALFI Position Paper is to outline ALFI’s recommendations by way of providing Best Market Practice Guidelines on the treatment of subscription and redemption orders under AIFMD.
This document contains the working group’s assessment of the current market practice across a representation of Luxembourg fund industry participants from the perspective of global cross-border fund servicing of Luxembourg-domiciled funds.
This document is not meant to impose an industry standard but is a guide to best market practice to comply with Commission Regulation (EU) N° 231/2013. This document has not been validated by any regulator. It does not diminish the management company’s or the asset servicing provider’s responsibility to comply with the EU Regulation and the CSSF circular on the treatment of subscription and redemption orders under AIFMD.
Some organizations may have different views based on their own assessment of the Commission Regulation (EU) N° 231/2013 in respect of Article 26 and Article 65. This ALFI Position Paper does not aim at imposing these recommendations but is to serve as a guideline to the industry participants on these primarily “operational” subjects related to Luxembourg’s fund industry infrastructure and operating model.
The document can be downloaded here.