The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), issued a new version of its CSSF - Frequently Asked Questions 6 July 2017 concerning the alternative investment fund mangers and alternative investment funds (AIFs) that are established in Luxembourg.
According the Regulation (EU) No 1286/2014 of the European Parliament and of the Council of 26 November 2014 on key information documents (KIDs) for packaged retail and insurance-based investment products (PRIIPs), all PRIIPs manufacturers must make available a PRIIPs KID to retail investors before they invest in these PRIIPs (including investment funds). The CSSF confirmed that manufacturers of Luxembourg AIFs have to issue this PRIIPs KID as of 1 January 2018.
Furthermore, the CSSF also advised that « the final version of a PRIIPs KID must be filed by adhering to the instructions provided in Circular CSSF 08/371 and in Circular CSSF 11/509 and by applying the nomenclature detailed in the information that is provided under the following link: Transmission électronique de documents à la CSSF".
Manual PRIIPs KID transmission to the CSSF
1. Manual file transmission via e-file v1 platform:
Please note that the e-file v1 transmission channel will not be available for the PRIIPs KID transmission
2. Manual file transmission via e-file v2 platform - Document Management:
(-) Upload your PRIIPs KIDs to Document Management. Select and transmit them to the CSSF.
(-) Upload your PRIIPs KIDs to your FTP account. Once the documents are available in Document Management, you have to select and transmit them manually.
Please note that filing automatism and suggestions are not yet available. They will follow in due course.
PRIIPS KIDs which are uploaded to Document Management have to comply with the Fundsquare naming convention (indexation level on share class):
Automatic KID PRIIPs transmission to the CSSF
PRIIPs KID can be sent via the Sending Service by dropping the file into the folder ReportingDiffusion\DOC_FIS_OPC\KID_OPC
PRIIPS KID which are transmitted to the CSSF via the Sending Service have to comply with the CSSF File name convention