On 7 August 2017, ALFI responded to the ESMA consultation on draft technical advice, implementing technical standards and guidelines under the Money Market Fund Regulation.
Click here for ALFI’s response.
On 11 July 2017 ALFI responded to the ESAs’ consultation on a draft joint RTS on measures to take to mitigate AML/CFT risks where a third country’s law does not permit the application of group-wide policies and procedures.
The consultation aimed at fostering a consistent approach to identifying and managing the ML/TF risk to which credit and financial institutions are exposed as a result of their operations in such countries and sets out minimum actions that should be taken in this context. In particular, issues such as individual money-laundering and terrorist financing risk assessments, customer data sharing and disclosure of information related to suspicious transactions are addressed in this paper.
Read the ALFI response.
The Association of the Luxembourg Fund Industry (ALFI) welcomes the European Commission’s initiative to create a regulatory framework for an innovative pan-European personal pension product (PEPP). ALFI believes that the investment fund industry in general, and Luxembourg’s internationally oriented fund sector in particular, can play a key role in facilitating long-term savings in Europe and in allowing individuals to build up additional retirement income.
ALFI has already expressed on many occasions its conviction that there is an urgent need to encourage second and third pillar retirement provisions to complete insufficient first pillar retirement provisions and that the asset management industry has an important role to play in this context.
ALFI therefore welcomes the fact that the PEPP is conceived as a new type of voluntary personal pension that can be used in parallel with existing state-based, occupational and national personal pensions.
It is also commendable that PEPPs should have the same standard features wherever they are sold in the EU and that they can be offered by a broad range of providers, such as insurance companies, banks, occupational pension funds, investment firms and asset managers.
It is of essential importance that PEPP providers benefit from an EU passport, allowing providers based in one EU Member State to offer personal pensions in other EU Member States and allowing savers to sign up for a personal pension offered in other EU Member States. This will offer consumers more choice.
Last but not least, the foreseen "portability" of the PEPPs, enabling savers to transfer the benefits accumulated in one or more Member State(s) when moving from one Member State to another is an important feature to foster the increasing – and necessary – mobility of workers within the EU.
“Luxembourg is very well positioned to support the swift uptake of the PEPP”, ALFI chairman Denise Voss says, “given its long standing experience in both (i) pass-porting funds such as UCITS across borders, as well as in (ii) setting-up and administering pension fund vehicles, in many cases as cross-border and multi-employer funds.
ALFI would like to highlight, however, that aside from considering the tax treatment for PEPPs, additional efforts at the level of investor education will be key to make the PEPP a true success story.”
 The Luxembourg law foresees three types of pension fund structures, the CAA (Commissariat aux Assurances) funds, the SEPCAV (Société d’Epargne-Pension à Capital Variable) or ASSEP (Association d’Epargne-Pension)
The Association of the Luxembourg Fund Industry (ALFI) welcomes the decision of MSCI to include China A-Shares (5%) into the MSCI Emerging Markets Index, resulting in an approximate weight of 0.73% in the index which was announced yesterday.
“The decision of the MSCI to include China A-shares into the MSCI EMI has been long awaited by all market participants. Over the past few years, authorities in China have embarked on an ambitious agenda for the liberalisation of capital markets in the mainland, which is now reaping benefits,” said Marc-Andre Bechet, Director of Legal and Tax Affairs at ALFI.
“The weight which is assigned to China A-shares is still modest compared to the size of China’s economy, now the second largest in the world. From a market stability standpoint, this is a smart move as it is unlikely to create any disruption in equity markets,” added Bechet.
Luxembourg has had a long tradition of acting as a facilitator for inbound and outbound investment in mainland China, particularly in the asset management sector.
“Luxembourg recognises the opportunity to act as the centre of reference for investors looking to gain access to China’s equity markets and beyond to invest in other asset classes. Luxembourg investment funds were the first European funds to make use of Stock Connect, as early as December 2014 for Shanghai HK Stock Connect and more recently in December 2016 for Shenzhen HK Stock Connect.
Similarly, QFII/ RQFII schemes have been used as early as 2002 (QFII) and 2013 (RQFII). Since the granting of a Luxembourg quota, seven Luxembourg-based institutions have been granted an RQFII licence and quota.
“In light of the MSCI decision, Luxembourg investment funds are ideally placed to take advantage of this new and strategic opportunity,” concluded Bechet.
The Association of the Luxembourg Fund Industry (ALFI) has re-elected Denise Voss for an additional two-years term as Chairman of its Board of directors.
Denise Voss has been a member of the ALFI board of directors since 2007 and has been Vice Chairman for International Affairs since 2011 before being appointed Chairman in June 2015. Denise is Conducting Officer of Franklin Templeton Investments and has worked in the financial industry in Luxembourg since 1990.
Before the Association’s Annual General Meeting held today at the Luxembourg Chamber of Commerce, an Extraordinary General Membership Meeting adopted a modernisation of the Association’s statutes. The main modifications concern the introduction of a limit on the number of consecutive terms of Board members and an adaptation of the annual membership fee calculation principles.
Fostering team work and cooperation between ALFI’s various bodies, its General Secretariat and its members who join efforts in the Association’s 150 Technical Committees and Working Groups will continue to rank as one of her top priorities for the next two years, Denise Voss said when presenting her program.
The implementation of regulation, including MiFID II, PRIIPS and the EU’s General Data Protection Regulation, or GDPR, will continue to occupy much of the industry’s time and resources in the years to come. In this context, providing input to consultations from both EU and non EU bodies as well as regular communication with the European institutions and the Luxembourg government should continue to be focus areas.
As the Luxembourg fund industry is moving towards 4,000 billion euros of assets under management, new structures and investment vehicles, including those used for non-traditional assets, have proven to be successful, and new jurisdictions such as Brazil and Australia have opened up to the distribution of Luxembourg funds. The impact of Brexit on the fund industry and businesses will be high on ALFI’s agenda over the next two years.
Denise Voss also stressed the importance of governance and of the role of the management company. “It’s vital that ALFI continues to explain the delegation model that the Luxembourg fund industry has operated over the last 30 years since the introduction of UCITS. The delegation model continues to be tried and tested in many industries throughout the world and in the case of UCITS brings the expertise of portfolio managers from around the world to investors in over 70 countries”, Denise said.
Talking about the opportunities offered by a rapidly changing environment, Denise Voss highlighted the asset management industry’s increasing role as a source of financing jobs and growth in Europe in the context of Europe’s Capital Markets Union and the chance – and need – to pro-actively use the arising digital technologies to improve the effectiveness and efficiency of the fund industry and its companies.
The ALFI chairman also expressed the conviction that the fund industry is now recognising its responsibility to engage with investors and fund distributors in respect of investor education, key to the financial well-being of individuals in and outside of Europe.
In order to best address the challenges the industry is facing, ALFI is adapting itself. Following a member survey, the Association has reviewed the governance of its internal bodies as well as the concept and organisation of its events – the first result having been the very well received transformation of the Spring conference into the ALFI European Asset Management Conference. Last but not least, a re-designed intranet went “live” in 2016 as a means of facilitating communication and exchange with and between ALFI members.
Read more about ALFI’s activities and achievements in the Associations online annual report.
ALFI’s new Board of Directors is as follows:
- Georges Bock, KPMG Luxembourg, S.C.
- Freddy Brausch, Linklaters
- Dirk Bruckmann, Deutsche Asset Management S.A.
- Stéphane Brunet, BNP Paribas Asset Management Luxembourg
- Michèle Eisenhuth, Arendt & Medernach
- Jacques Elvinger, Elvinger Hoss Prussen S.A.
- Michael Ferguson, Ernst & Young S.A.
- Bettina Graeber, Pictet & Cie (Europe) S.A.
- Jonathan P. Griffin, JPMorgan Asset Management (Europe) S.à r.l.
- Holger Hildebrandt, Deka International S.A.
- Lou Kiesch, Deloitte General Services S.à r.l.
- Rudolf Kömen, Credit Suisse Fund Management S.A.
- Nils Kruse, GAM (Luxembourg) S.A.
- Steven Libby, PricewaterhouseCoopers, Société Coopérative
- Maria Löwenbrück, Union Investment Luxembourg S.A.
- Geoff Radcliffe, BlackRock Fund Management Company S.A.
- Gilbert Schintgen, UBS Fund Management (Luxembourg) S.A.
- Thomas Seale, European Fund Administration S.A.
- David Suetens, State Street Bank Luxembourg S.C.A.
- Denise Voss, Franklin Templeton International Services S.à r.l.
- Marc Wathelet, FIL (Luxembourg) S.A.
- Revel Wood, FundRock Management Company S.A.
- Alastair Woodward, Schroder Investment Management (Luxembourg) S.A.
- Julien Zimmer, DZ PRIVATBANK S.A.
Download a picture of the new ALFI Board of Directors.
ALFI annual report website is now online !
For its 2016-2017 report, ALFI created a dedicated website to facilitate access to key information and activities of the association.
ALFI responded to the EU Commission Consultation "FinTech - A more competitive and innovative European financial sector".
The consultation document is the product of the work of the dedicated EC Task Force on Financial Technology, seeking input from stakeholders to further develop the Commission's policy approach towards technological innovation in financial services.
The document is structured around 4 main parts:
- Fostering access to financial services for consumers and businesses, where artificial intelligence and data analytics for robo advice and execution feature prominently, alongside crowd funding and sensory data analytics;
- Bringing down operational costs and increasing efficiency for the industry through the use of regulatory requirements (“Regtech”), cloud computing, Block Chain/Distributed Ledger Technology (DLT) or outsourcing of non-core business functions.
- Making the single market more competitive by lowering barriers to entry, e.g. via financial services legislation, supervisory practices that need to be adapted and industry standards. This section includes a question about the financial stability challenges related to FinTech.
- Balancing greater data sharing and transparency with data security and protection needs, raising questions around the use of “Big Data” and cyber security.
Download the ALFI response here.
Educating individuals on the value and importance of investment is the asset management industry’s biggest challenge according to a live poll carried out at the ALFI London Conference in May, with one in three (33%) respondents agreeing with this. In a similar poll at the ALFI European Asset Management conference in March, 96% of respondents believed that there is a need to improve investor education.
In the London poll, respondents believed that the other major challenges faced by the industry are new digital entrants (25%), regulatory changes brought on by geopolitical changes (23%), and fragmented distribution markets (17%). 61% of London respondents also believed that the regulatory framework could have the most significant impact on the shape of the asset management industry in five years’ time, whilst 27% thought that the level of investor education would have the most significant impact.
ALFI London conference took place on 23 May 2017 (Central Hall Westminster).
In terms of digital strategies for asset managers in the Luxembourg poll, 88% believe that social media is important to asset managers. In addition, 49% believed that the digital compliance issue is surmountable and said they are tackling it, while 11% believed that compliance is an insurmountable hurdle and 40% say that compliance is insurmountable and that there is no internal appetite to tackle this.
Polling at the conferences also showed:
- 53% of respondents in London believed that the core role of the asset management industry in 50 years’ time will be to provide long term savings vehicles directly to private investors, whilst 19% believed that the role will be as a manufacturer of fund products for digital distributers and 7% as a manufacturer for robo-advisers. 21% believed that the asset management industry’s key role will be as a driver of the economy.
- 94% of respondents in Luxembourg believed that there will be more consolidation in the funds industry.
- 67% of respondents in Luxembourg believed that regulation has improved investing for the end investor over the last 10 years.
- 94% believed that product availability has improved over the last ten years.
“The industry is going through considerable adaptation, not only as a result of the changing regulation but also changing technology, the developing environment of geopolitical change, demographic evolution and the need for people to take responsibility for their own long-term financial security,” said Denise Voss, Chairman of ALFI. “Attendees at our conferences are generally positive – 81% at our Luxembourg conference said they were optimistic about the fund industry – but recognise the challenges that lie ahead.”
- Ends -
Download the press release in English.
For further information:
Senior Communications Manager
Tel: +352 22 30 26 - 1
Notes to editors:
 At the ALFI European Asset Management Conference in March 2017 there were 650 attendees from the asset management industry, including service providers. See the conference report and the photo gallery.
 At the ALFI London Conference in May 2017 there were 800 attendees from the asset management industry, including service providers. See the photo gallery.
The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. Created in 1988, the Association today represents over 1500 Luxembourg domiciled investment funds, asset management companies and a wide range of service providers such as custodian banks, fund administrators, transfer agents, distributors, legal firms, consultants, tax experts, auditors and accountants, specialist IT providers and communication companies. The Luxembourg Fund industry is the largest fund domicile in Europe and a worldwide leader in crossborder distribution of funds. Luxembourg-domiciled investment structures are distributed on a global basis in more than 70 countries with a particular focus on Europe, Asia, Latin America and the Middle East. For further information, do not hesitate to consult our website at www.alfi.lu
On 16 May 2017, ALFI responded to the European Commission consultation on the operations of the European Supervisory Authorities. The response mainly focuses on the status of non-binding measures issued by the ESAs, consumer and investor protection issues, and direct supervisory powers in the investment fund segment of the capital markets.
Download the ALFI response here.