Key regulatory changes affecting investment compliance, including risk assessment and portfolio management.
Monthly Updates
📅 Last Updated: 31/03/2025
| Sub Category | Region | Earliest Adoption Date (Can Apply) | Latest Adoption Date (Must Apply) | Update Title | Short Description | Details | FA Product Impact | Status | FA Outreach | Source Link |
|---|---|---|---|---|---|---|---|---|---|---|
| All | EU | N/A - proposal only | N/A - proposal only | Review of EU Eligible Assets Directive | Review of EU Eligible Assets Directive | ESMA also had a Call to Evidence on amending the UCITS Eligible Assets Directive | Yes - but unknown until formal legislation issued | Watching brief | ||
| CIS - Liquidity Risk Management | EU | Consultation completed - waiting final report | Consultation completed - waiting final report | IOSCO consultations on liquidity risk management for CIS, including OEFs | The International Organization of Securities Commissions (IOSCO) Publishes Consultation Report on Updated Liquidity Risk Management Recommendations for CITs on 11 Nov 2023 and held a consultation on its revised recommendations that closed on 11 February 2025 and IOSCO aims to produce its final report in the first half of 2025. | IOSCO proposed 17 recommendations to Liquidity Risk Maagement(LRM) organised into 6 sections namely: CIS Design Process, Liquidity Management Tools and Measures, Day to-Day Liquidity Management Practices, Stress Testing, Governance and Disclosures to Investors and Authorities. The main topics of revision include: Categorizing open-ended funds (OEFs) based on the liquidity of their assets • Encouraging investment managers to implement a broad set of liquidity management tools (LMTs) and measures. • Emphasizing the importance of anti-dilution LMTs to mitigate material investor dilution and potential first-mover advantage arising from structural liquidity mismatch in OEFs. • Incorporating new guidance on quantity-based LMTs and other liquidity management measures | Yes - to be discussed | Watching brief/ impact on clients | Click to View | |
| NAV Calculation | LUX | Mar 29 2024 | Jan 1 2025 | Circular CSSF 24/856: Protection of investors in case of an NAV calculation error, instances of non-compliance with the investment rules and other errors at UCI level | CSSF published Circular 24/856 published on 28 March 2024 comes to effect from 1 January 2025, repealing CSSF Circular 02/77 Scope: UCITS, Part II UCIs, SIFs and SICARs, as well as MMFs set up as a UCITS, Part II UCI or SIF and ELTIFs, EuVECAs and EuSEFs set up as Part II UCIs, SIFs or SICARs as well as MMFs, ELTIFs, EuVECAs and EuSEFs which are not authorized as UCITS, Part II UCIs, SIFs and SICARs, but for which the CSSF is the competent authority in accordance with the applicable product regulations. | NAV Tolerance Thresholds: - Money market UCIs : prev: 0.25%; new: 0.20% - UCIs which invest primarily in other eligible assets: prev: NA; new: 1% - UCIs which invest primarily in bonds and/or other debt securities and UCIs which pursue a mixed investment policy, remains unchanged at 0.50% - UCIs which invest primarily in shares and/or other securities comparable to shares, remains unchanged at 1% Active and passive instances of non-compliance with investment rules resulting from: - Voluntary acts or operations, mainly linked to investment/divestment decisions - The absence of acts/operations when the non-compliance was avoidable and should have been able to be anticipated. UCIs must use either the accounting or the economic method to calculate and measure the impact this breach has caused. Other errors: UCIs to compensate loss due to errors arising from the incorrect application of anti-dilution tools (Swing price) UCIs to accrue errors resulting from costs/fees and compensate by performing correction procedures including re-calculation of the NAV over the entire period Where cut-off times outlined in prospects are missed, UCI must take corrective measures to ensure investors’ subscription/redemption orders have been carried out in accordance with such documents For investment allocation errors, a UCI must be indemnified the amount of the loss suffered by the misallocation. For error/non-compliance at the level of a UCI, compensation is to be paid to investors,(UCI/IFM must ensure that the final beneficiaries receive the compensation). Notification: Any error/non-compliance must be notified to the CSSF using the notification form which is provided for and made available on the CSSF website, within four to eight weeks maximum after the date of detection of the error/non-compliance; and as soon as possible, where more complex errors/instances of non-compliance involving multiple investors in a variety of jurisdictions is involved. For error/non-compliance concerns a UCITS or a Part II UCI where total amount of compensation is > EUR 50,000 or the amount to be compensated for a single investor is >EUR 5,000 a special report must be issued to CSSF within three months from submission of the notification form. | To be discussed | Notofied to BAU team | NA | Click to View |
| UCITS and AIFMD General | UK | 20/12/2024 | FCA COLL UCITS HB Notice 125 NURS investing into LTAFs | For NURS investing into LTAFs, removal of the requirement that the fund invested into must restrict investment in other CIS to max 15% NAV. | For NURS investing into LTAFs, removal of the requirement that the fund invested into must restrict investment in other CIS to max 15% NAV. The FCA has also clarified the application of teh requirement in respect of Max 20% in unregulated securities and unregulated schemes applies. There are also other impacts as regards the definition of "Unregulated Funds" which will impact on any funds investing into a QIS/QIAIF etc where they have determined they to be eligible. | Yes | Click to View | |||
| UCITS and AIFMD General | UK | 30/01/2025 | FCA COLL UCITS HB Notice 126 Concentration Rules | The FCA confirm that the UCITS concentration rules should apply at the sub-fund level as opposed to Umbrella level. | The FCA confirm that the UCITS concentration rules should apply at the sub-fund level as opposed to Umbrella level. There are also considerations for the target fund invested into and also exemptions for investment into other funds of the same Manager, | Yes | Implement by 28 feb 2025 | Approach to be confirmed with clients | Click to View | |
| Investment Compliance | US | 11/06/2026 | US Rule 35d-1 (Names Rule) | SEC has adopted teh Funds names rule. This will require funds to refrain from naming conventions that are likely to mislead investors, with a focus on ensuring that funds with names that suggest a particular investment focus adopt an investment policy that evidences at least 80 percent of the value of the fund's assets will be invested in the industry, type of investment, or geographic region suggested by the fund's name. | SEC has adopted the Funds names rule. This will require funds to refrain from naming conventions that are likely to mislead investors, with a focus on ensuring that funds with names that suggest a particular investment focus adopt an investment policy that evidences at least 80 percent of the value of the fund's assets will be invested in the industry, type of investment, or geographic region suggested by the fund's name. Larger funds were originally being required to comply by December 11, 2025, and smaller funds being required to comply by June 11, 2026. However, the SEC has extended both fund groups dates of compliance by six months, with larger funds now being required to comply with the Amendments by June 11, 2026, and smaller funds being required to comply with the Amendments by December 11, 2026. | Yes |