On 19 June 2015 ALFI responded to the EBA consultation paper on draft guidelines on limits on exposures to shadow banking entities. The EBA proposes, in the absence of a definition of “shadow banking entities”, to include alternative investment funds and money market funds under the definition of shadow banking entities which carry out banking activites outside a regulated framework. To read the full response please click here.
ALFI annual report 2014-2015 presents facts and figures on the development of the Luxembourg investment fund industry and the activities of our association. Link to flip book version. Older editions can be found here.
The Association of the Luxembourg Fund Industry (ALFI) today unveiled its “Ambition” for the next four years, led by new chairman, Denise Voss.
Denise Voss explained: “We have identified a number of factors that will impact the fund industry over the next few years related to consumer trends, demographics and technology, as well as shifts in the asset management industry itself.”
“It’s important that, as an industry, we anticipate and address these shifts if we are to continue to serve the interests of investors and the economy. To underpin this, we are committed to strengthening Luxembourg’s position as the international fund centre of reference, recognized as open, reliable and innovative by investors, policymakers and industry alike.”
In order to achieve its ambition, ALFI has set itself five key objectives for the next four years:
- Promote practices that align the interests of investors and industry by helping asset managers ensure that their practices, products and services match their clients’ needs in an era of global, digital distribution;
- Articulate the essential role of investment funds for the global economy by demonstrating how funds help resolve long-term issues of funding pensions, financing innovation and infrastructure, and contribute to growth;
- Connect investors with worldwide market opportunities by continuing to facilitate cross-border fund distribution for the benefit of the global community of investors who wish to participate in economic growth practically anywhere in the world;
- Ensure Luxembourg remains the fund centre of choice for asset managers by offering asset managers the best access to global distribution, deep and competitive talent and servicing infrastructure, outstanding corporate governance, an efficient and effective approval and oversight process, and a clear regulatory and taxation framework;
- Stimulate innovation, research, education and talent development by encouraging academic research related to the investment fund sector, supporting the development of new retail investor technologies and applications with a particular focus on the next generation of investors, as well as expanding professional training programs to broaden and deepen the talent pool for the global fund industry.
Ms Voss concludes: “Luxembourg has played a key role in helping asset managers work through the implementation of extensive regulation after the crisis and has created effective solutions for asset managers, enabling them to distribute their funds globally. We must now also address the shifts in demographics and technology if the industry is to continue to play its role of serving the interests of investors and of the economy.”
The Association of the Luxembourg Fund Industry (ALFI) today announced the appointment of Denise Voss as chairman of ALFI. Ms Voss takes up the position, which will initially run for two years, with immediate effect.
“I am very excited about this appointment,” said Ms Voss. “The asset management industry in Europe has gone through dramatic change over the past few years, with extensive regulation that has been put in place following the crisis, and ALFI has played a key role in working through the implementation of this regulation.”
”Going forward, we face different challenges, for instance, from the greying of the population and more and more individuals being responsible for funding their own retirement, to the growth of digital technology, which means that buying habits are changing dramatically. My role is to inspire the industry to focus on these issues and to ensure that the Luxembourg Fund Industry continues to play a key role in driving the development of the industry worldwide, encouraging economic growth and providing long-term financial security for individuals.”
Denise Voss has played a key role in ALFI for many years. She has been Vice Chairman for International Affairs of ALFI since 2011 and has been a member of the ALFI board of directors since 2007. She is also Chairman of the European Fund and Asset Management Association (EFAMA) Investor Education working group.
Denise is Conducting Officer of Franklin Templeton Investments and has worked in the financial industry in Luxembourg since 1990. She joined Franklin Templeton Investments in 1995 where she is Conducting Officer of Franklin Templeton International Services S.à r.l., a Luxembourg-based management company, managing both UCITS and AIFs, in and outside of the EU.
Prior to joining Franklin Templeton Investments, Denise worked in the audit division of Coopers & Lybrand in Boston, USA and Luxembourg for over 9 years. Denise holds a Massachusetts C.P.A. license and obtained an undergraduate degree from Tufts University, as well as a masters degree in accountancy from Bentley College.
The new Board of Directors is as follow:
Georges Bock, KPMG Luxembourg Société cooperative
Freddy Brausch, Linklaters LLP
Stéphane Brunet, BNP Paribas Investment Partners Luxembourg S.A.
Martin F. Dobbins, State Street Bank Luxembourg S.A.
Jacques Elvinger, Elvinger, Hoss & Prussen
Michael Ferguson, Ernst & Young S.A.
Noel Fessey, Schroder Investment Management (Luxembourg) S.A.
Rafik Fischer, KBL European Private Bankers S.A.
Bettina Graeber-Hendry, Pictet & Cie (Europe) S.A.
Jonathan P. Griffin, JPMorgan Asset Management (Europe) S.à r.l.
Ewald Hamlescher, GAM (Luxembourg) S.A.
Rudolf Kessel, Union Investment Luxembourg S.A.
Lou Kiesch, Deloitte Luxembourg
Rudolf Kömen, Credit Suisse Fund Management S.A.
Claude Kremer, Arendt & Medernach S.A.
Eugen Lehnertz, Deka International S.A.
Steven Libby, PricewaterhouseCoopers, Société Coopérative
Markus Nilles, Allianz Global Investors GmbH, Zweigniederlassung Luxembourg
Geoff Radcliffe, BlackRock (Luxembourg) S.A.
Gilbert Schintgen, UBS Fund Management (Luxembourg) S.A.
Thomas Seale, European Fund Administration S.A.
Denise Voss, Franklin Templeton Investments
Marc Wathelet, FIL Investment Management (Luxembourg) S.A.
Julien Zimmer, DZ Privatbank S.A.
On 4 June 2015, ALFI responded to the EBA consultation on draft guidelines on sound remuneration policies under Article 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013.
Issues adressed in the paper relate, among others, to the definition of staff, remuneration policies and group context, proportionality, and equivalence of remuneration rules for CRD IV, AIFMD and UCITS. The full response can be read here.
On 29 May 2015, ALFI responded to the second FSB and IOSCO consultation on “Assessment methodologies for identifying non-bank non-insurer global systemically important financial institutions (NBNI G-SIFIs)”.
ALFI is of the view that highly regulated funds such as UCITS or regulated Alternative Investment Funds that comply with detailed diversification rules and are not highly leveraged are not systemically important and do not cause systemic risk. Moreover, ALFI believes asset managers are not a source of systemic risk. Managers are not the counterparty to trades they conduct on behalf of their clients (agency model). It is worth noting that many funds and asset managers exit the business every year, without giving rise to systemic risk.
As further explained in the response, ALFI considers it more appropriate to focus on market activities, such as the use of high leverage and derivatives that may cause systemic risk to the financial system.
Join us for the fifth NICSA webinar in the series sponsored by ALFI, reviewing developments in the fund industry outside the United States and their impact on U.S. fund managers.
Trialogues? Comitology? The European Council? The Council of the European Union? Have you heard these terms and wondered, "What exactly do they mean"?
U.S. asset managers are often baffled by securities rulemaking in the European Union. This webinar will provide an introduction to the players and process in Europe -- and how it differs from the U.S. approach. You'll get both the American and European perspectives. Theresa Hamacher, President of NICSA, will translate Eurospeak into American terms. Antoine Kremer, head of the EU representative office in Brussels for Luxembourg fund industry association ALFI, will explain what happens behind the scenes and provide insights on trends.
The webinar will be moderated by Theresa Hamacher, President of NICSA, Boston, speaker: Antoine Kremer, Head of EU Representative Office in Brussels, ALFI.
You can submit a question in advance to firstname.lastname@example.org.
The webinar is free of charge. To register, please refer to this link.
The ALFI&ALRiM European Risk Management conference took place on May 20 2015, and was attended by more than 240 delegates.
Conference in a nutshell
The ALFI&ALRiM European Risk Management conference took place on May 20 2015, and was attended by more than 240 delegates.
In their introductory speech to the conference, Camille Thommes (Director General, ALFI) and Marco Zwick (President, ALRiM) highlighted the strong evolution of the AuM in the investment fund industry in Luxembourg and insisted on the reinforcement of the Risk Manager’s role in this rapidly evolving environment.
During the day, different topics have been addressed with amongst others:
- Operational risk;
- Key learnings of the implementation of the AIFMD risk management principles;
- Current state of the financial and potential triggers of the next financial crisis;
- The relationship between the portfolio management activities and the risk management.
From these different sessions, we can retain some key messages which will probably complete the roadmap of the Risk Managers for the coming years:
- Regarding Operational risk within the investment fund industry, panellists insisted on the fact that while most of the market, credit and liquidity risk factors are now usually properly monitored, the risks related to the distribution needs increased attention and more systematic monitoring.
- If Risk Management is viewed as adding value to the business, the past experience and industry expertise of Risk Managers appeared as a key points to consider.
- Looking for a Risk Manager who masters all investment strategies pursued by AIFs (i.e. Hedge Funds, Real Estate and Private Equity) sounds as an unrealistic challenge. It is then probably recommended to look for a team of Risk Managers, specialized per asset class or share that activity with other experts.
- The relationship between the Portfolio Manager and the Risk Manager, the transparency requirements and the liability of the Risk Managers are all increasing and should not be underestimated.
The conference ended-up with the feedback from representatives of both the Luxembourg and the German Regulator on some technical topics as well as the next steps in the development of the regulatory environment.
Overall, the 6th ALFI/ALRiM Risk Management Conference highlighted clearly that risk management is a key component of the governance framework of asset managers and as such also of paramount importance for senior management as well as for Board of Directors of Management Companies.
The photos of the conference can be viewed here.
On 18 February 2015, the EU Commission presented a consultation on an EU framework for simple, transparent and standardised securitisation. The wish to create a sustainable market for high-quality securitisation which is part of the Commission’s Investment Plan for Europe announced on 26 November 2014 was identified as one of the five areas where short-term action was needed.
A high-quality EU securitisation framework will promote further integration of EU financial markets, help diversify funding sources and unlock capital, making it easier for banks to lend to households and businesses.
In terms of building a market for high-quality securitisation, the Commission, together with other European authorities and central banks, has encouraged the development of a framework that better reflects the different characteristics of securitisations within the strengthened EU regulatory environment. The first step is to identify sound instruments based on clear eligibility criteria. The second step is to adjust the regulatory framework to allow a more risk-sensitive approach.
The document can be downloaded here.
On 18 February 2015 the European Commission presented its Green Paper on building a Capital Markets Union (“CMU”). The CMU project was announced in July 2014 by EU Commission President Juncker as part of his five-year agenda and a key part of the EU Commission’s 10 priorities. In its political ambition, it seeks to remove barriers to the free flow of capital in Europe, and increase the role that market-based finance plays in intermediating capital to European companies, projects and governments.
Download the document here.