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. This document contains the ALFI UCITS IV Operations Working Group’s (serving under the ALFI TA & Distribution Forum) 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 CSSF Regulation N° 10-4, Article 16 on Recording of subscription and redemption orders and, Article 27 on Reporting of subscription and redemption orders. This document has not been validated by any regulator. It does not diminish the management company’s, the Asset Manager and/or the third party asset servicing (specifically in this instance, the registrar and Transfer Agent) provider’s responsibility to comply with the EU Regulation or CSSF circular on the treatment of subscription and redemption orders under UCITS IV.
Some organizations may have different views based on their own assessment of the CSSF Regulation N° 10-4 transposing Commission Directive 2010/43/EC of 1 July 2010 in respect of Article 16 and Article 27. This ALFI Position Paper does not aim at imposing these recommendations.
Position Paper on the CSSF Regulation N° 10-4 Members only