CSDR – from a custodian standpoint

The ALFI Depositary Forum has provided valuable input to the ALFI CSDR considerations on certain implications of the settlement discipline regime (SDR) regarding the allocation of cash penalties by the custodians to the funds.

AIFMD review

The working group in charge of the depositary aspects of the AIFMD was convened right after the release of the AIFMD review proposal in November 2021. Clarification was requested from the European Commissions as regards the national derogation allowing the appointment of a depositary in a different member state from that of the AIF, as well as on which type of CSD should be considered as a delegate of the depositary when involved in the custody chain.


ALFI continues to be the voice of Luxembourg at the European Trustee and Depositary Forum (ETDF), in particular on the above items. The association regularly interacts with the other national associations involved in the depositary field on the topics at issue.

François Baratte, Senior Industry Affairs Advisr