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This document presents an assessment of the current market practice, across a representative sample of Luxembourg fund industry participants, prepared by the ALFI UCITS IV Operations Working Group’s (serving under the ALFI TA & Distribution Forum). The recommendations are given 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 and Article 27 on Reporting of subscription and redemption orders. This document has not been validated by any regulator. It does not diminish the responsibility of the management company, the asset manager and/or the provider of third party asset servicing (specifically, in this instance, the registrar and transfer agent) to comply with the EU Regulation or CSSF circular on the treatment of subscription and redemption orders under UCITS IV.
Some organisations 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. It is not the aim of this ALFI Position Paper to impose these recommendations on readers of the Paper.