Fund News - Issue 116 - June 2014

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FUND NEWS Financial Services / Regulatory and Tax / Issue 116 Developments in June 2014 Investment Fund Regulatory and Tax developments in selected jurisdictions

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Issue 116 of Fund News covers the recent publication of MiFID II and MiFIR in the Official Journal of the EU as well as the updated Q&A on AIFMD and EMIR Implementation by the ESMA.

Transcript of Fund News - Issue 116 - June 2014

Page 1: Fund News - Issue 116 - June 2014

FUND NEWS

Financial Services / Regulatory and Tax / Issue 116

Developments in June 2014 Investment Fund Regulatoryand Tax developments in selected jurisdictions

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2 / Fund News / Issue 116 / Developments in June 2014

Regulatory Content

European Union 3 MiFID II / MiFIR published at the Official Journal of

the EU 3 ESMA updates Q&A on AIFMD 4 ESMA updates Q&A on EMIR implementation

Belgium 5 Belgium transposes the AIFMD

Ireland 6 IFIA Annual Global Funds Conference 7 CBI publishes Discussion Paper on Risk Appetite 7 Key Dates Reminder

Luxembourg 8 The CSSF and the BCL issued a Circular on the

modification of the statistical data collection for money market and non-monetary market investment funds

Switzerland 9 Guidelines on Duties Regarding the Charging and

Use of Fees and Costs (Transparency Guidelines)

International 10 IOSCO consults on Good Practices on Reducing

Reliance on Credit Rating Agencies

Contents

Tax News

Belgium 11 B-REIT: alternative to the Belgian real estate

investment company (“Vastgoedbevak / SICAFI Immobilière”)

New KPMG Report 12 Evolving Investment Management Regulation –

Clarity leads to opportunity

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Fund News / Issue 116 / Developments in June 2014 / 3

Regulatory News

ESMA updates Q&A on AIFMD

On 27 June 2014 the European Securities and Markets Authority (ESMA) issued updated Questions and Answers (Q&A’s) on the application of the Alternative Investment Fund Managers Directive (AIFMD) with a focus on remuneration, regulatory reporting and AIFM management passport notification.The Q&A’s clarify the following points:

• AIFMs cannot choose to exclude portfolio managers from the scope of identified staff for the purpose of the remuneration guidelines purely because they are bound by investment limits set out by law and / or internal risk limits set out in the investment restrictions of the AIF;

• EEA AIFs and EEA AIFMs should be understood as AIFs and AIFMs established in one of the 28 EU Member States or Iceland, Norway and Liechtenstein;

• A reference to “the Union” refers to the 28 EU Member States and, once the AIFMD has been incorporated into the EEA agreement, Iceland, Norway and Liechtenstein;

• Information marked as mandatory (M) in the reporting template should be reported by all AIFMs. Further, information marked as optional (O) has to be reported if the AIFM has information to report, e.g. an information item that has changed compared to the previous reporting. Furthermore, information marked as conditional (C) is linked to other information in the reporting template. If answered with “Yes”,

the corresponding conditional information has to be reported, while nothing needs to be reported in the case of “No”;

• An AIFM may manage an AIF in a host Member State (MS) under Article 33 of the AIFMD without having identified any existing AIF in that host MS beforehand. In practice, it may be necessary for an AIFM to first notify its wish to make use of the management passport in order to subsequently be in a position to create and manage AIFs in that host MS;

• If the AIFM has no prior presence in the host MS it is sufficient for the AIFM to specify the types of strategies of the AIFs it intends to manage in the host MS. However, this is without prejudice to the obligation for the AIFM to communicate a program of operations stating the services it intends to perform in the host MS;

• In relation to the passport for MiFID services provided by an AIFM, MiFID II amends the AIFMD to effectively allow these services to be passported (these measures will be effective on 3 July 2015). In the meantime the Q&A refers to “the principle of sincere cooperation” in the TFEU which should mean that Member States would accept this passport before 3 July 2015.

The text of the Q&A is available at the following web link.

http://www.esma.europa.eu/system/files/esma_2014-714_-_qa_on_aifmd_june_update_for_publication.pdf

MiFID II / MiFIR published at the Official Journal of the EU

Two and a half years after the release of the proposal for a recast of the Markets in Financial Instruments Directive (MiFID) and for a new regulation on Markets in Financial Instruments (MiFIR), both texts were published at the Official Journal on 12 June 2014. They shall enter into force on 2 July 2014 and will be applicable 30 months later (i.e. by 2 January 2017). In the meantime, the European Securities and Markets Authority (ESMA) and the European Commission will have 18 months to develop the level 2 measures implementing MiFID II / MiFIR. As outlined in the Fund News of May 2014, ESMA is currently consulting on the level 2 measures.

The text of MiFID II can be found at the following web link

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2014_173_R_0009&from=EN

and the text of MiFIR is available at the following web link.

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2014_173_R_0005&from=EN

European Union

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ESMA updates Q&A on EMIR implementation

On 24 June 2014 ESMA issued updated Questions and Answers (Q&A’s) on the implementation of the European Markets Infrastructure Regulation (EMIR) with a focus on the daily reporting requirement for valuations and collateral for financial counterparties. The Q&A’s clarify:

• With the upcoming collateral reporting deadline on 12 August 2014, the Q&A spell out specific answers related to the collateral reporting requirements, e.g. the reporting base currency if collateral is reported on a portfolio basis; clarifies that only posted collateral should be reported to trade repositories (TRs) to avoid double-counting, etc.;

• Given the upcoming valuations reporting deadline on 12 August 2014, the Q&A provide guidance on mark-to-market value calculation as well as mark-to-model valuations of an OTC derivative contracts. In addition, the Q&A states that even though reporting, including valuations, may be delegated to third parties the delegating counterparties remain liable for the reporting requirement;

• Reporting empty fields to TRs in the specified reporting form should only be done under not relevant cases. The Q&A define relevant and not relevant cases;

• Counterparties reporting valuations of complex contracts related to the same trading strategy should be reported separately and the valuation should be reported on a per contract basis;

• Collateralization fields in the reporting form to TRs must be labeled uncollateralized, partially collateralized, one-way collateralized or fully collateralized. The Q&A defines each term;

• Contracts with no maturity date, such as CFDs, have to be reported by the counterparties for each opening of a new contract as a new entry and a termination report is send to the initial entry. Every time the contract is closed partially, counterparties send a modification report to the initial entry, reducing only the notional amount (remaining value equal the not yet terminated);

• The notional amount field in the reporting form to TRs should reflect the original value of the contract initially. When the nominal value is increased or decreased as result of lifecycle events or if the quantity changes then the nominal amount should be updated with a modification report send by the counterparties;

• OTC derivatives novations, wherein one party exits the existing transaction and the other counterparty remains, are to be reported first through a termination report marked as “cancelled” by the two original counterparties to the TR. The remaining counterparty and new counterparty have to send a new report relating to the new transaction to the TR;

The text of the Q&A is available at the following web link.

http://www.esma.europa.eu/system/files/esma_2014-714_-_qa_on_aifmd_june_update_for_publication.pdf

Regulatory News

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Belgian transposes the AIFMD

On 17 June 2014, the Belgian law transposing the AIFMD was published at the Official Gazette. The Belgian government ratified the law on 19 April 2014. The law will enter into force 10 days after his publication, on 27 June 2014.

The Belgian law on AIFM (so called “loi OPCA”) is structured in three main parts as follows:

• Part II concerns harmonized requirements applicable to AIFM with a chapter regarding the authorization and another on the passport;

Belgium

Regulatory News

• Part III contains the non-harmonized requirements concerning AIF. Those are applicable to the AIF under a legal status as follow:

– to the AIF under Belgian or foreign law which are subject to a public offer in Belgium, and

– to the Belgian non-public AIF that are going for one of the institutional or private legal status (sicafi institutionnelle, sicav institutionnelle and pricaf privée).

• Part IV contains the non-harmonized provisions of AIF management companies. Those are coming from the law of 3 August 2012 and are applicable to Belgian or foreign management companies that manage public AIF under the Belgian law.

The application files to be authorized as an AIFM must be sent by 22 July 2014 at the latest.

The text of the law of 19 April 2014 on AIFM is available at the following web link.

http://www.ejustice.just.fgov.be

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Regulatory News

IFIA Annual Global Funds Conference

On 18 June 2014 the Irish Funds Industry Association (the “IFIA”) held its annual funds conference in Dublin. Among the speakers was Gareth Murphy, Director of Markets Supervision at the Central Bank of Ireland. Mr Murphy discussed a number of topics including that:

• the Central Bank intends to consult on a new chapter to the AIF rule book regarding loan origination by AIFs. We reported on the Central Bank’s discussion paper on loan origination by fund in Issue 105 of Fund News (July 2013);

• the Central Bank will be able to process ICAV authorisations within two weeks of the enactment of the ICAV legislation. The Taoiseach

Ireland

(Prime Minister), Enda Kenny had noted earlier in the conference that the Irish government is prioritising the passage of the ICAV bill through the legislative process, hopefully before the end of July 2014. We reported on the ICAV in Issue 111 of Fund News (January 2014);

• the Central Bank will continue its work on adding clarity to the regulatory framework on client assets regarding the subscription and redemption accounts for funds;

• the use of outsourcing at fund service providers and managers is one of the areas of particular interest in the Central Bank’s themed inspections;

• the Central Bank intends to review the uptake of the IFIA’s voluntary code on corporate governance;

• the Central Bank intends to examine the situation of directors with large numbers of directorships in relation to their capacity to deliver on their directorial commitments and to manage their conflicts of interest; and

• the Central Bank is currently processing approximately 65 AIFM applications and that, once authorised, the Central Bank will carry out spot-checks on AIFM compliance as part of the themed-inspections in 2015.

The full text of Mr Murphy’s speech can be found here:

http://www.centralbank.ie/press-area/speeches/Pages/GarethMurphyIFIA2014.aspx

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Fund News / Issue 116 / Developments in June 2014 / 7

CBI publishes Discussion Paper on Risk Appetite

On 20 June 2014 the Central Bank published a discussion paper on the importance of an effective risk appetite framework for firms regulated by the Central Bank.

The Central Bank is of the view that the board is ultimately responsible for risk management and strategy and the paper sets out that risk appetite must be considered with strategy because they are fundamentally interlinked.

A copy of the discussion paper is available here:

http://www.centralbank.ie/regulation/poldocs/dispapers/Documents/Risk%20Appetite%20Paper.pdf

Key Dates Reminder

• 30 June 2014 The end of the first reporting period for AIFMs reporting quarterly and semi-annually. Period to be reported by 11 September 2014. See Issue 113 of Fund News (March 2014).

• 30 June 2014 Deadline for filing the “Investment Funds Annual Sub-Fund Profile Return” on the Central Bank’s Online Reporting System (“ONR”). See Issue 115 of Fund News (May 2014).

• 1 July 2014 FATCA withholding start date for FDAP (Fixed or determinable annual or periodical payments such as US source interest, dividends,

Regulatory News

royalties). The Final Irish Regulations on FATCA are expected to be released in the coming weeks. See Issue 112 of Fund News (February 2014) and KPMG Ireland’s latest publications on FATCA:

http://kpmg.newsweaver.com/1uk96as92v71buwl3wwxdn?email=true&a=11&p=47587102

http://kpmg.newsweaver.com/1e5zwaf14f6u1bl50qrdou?email=true&a=11&p=47655035

• 22 July 2014 End of the transitional period for EU AIFM. Non-EU AIFM can continue to market both EU and non-EU AIF to professional investors subject to additional reporting obligations.

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The CSSF and the BCL issued a Circular on the modification of the statistical data collection for money market and non-monetary market investment funds

On 28 May 2014, the CSSF and the BCL jointly issued a Circular on the modification of the statistical data collection for money market and non-monetary market investment funds in order to modify their system to collect data for statistical and prudential purposes.

Targeting all the Luxembourg UCI and the SICAR, the CSSF new circular 14 / 588 is aligned within the framework of the new Regulation (EU) No 549 / 2013 on the European System of national and regional accounts in the European Union.

The circular defines the following main rules:

• Objectives of collecting data

• Main modifications such as new versions of the current reporting and an extension of the scope of the statistical reporting to the SICAR.

Luxembourg

• The definition of monetary Investment funds and a list of all investment funds or sub-funds of monetary investment funds maintain and published by the CSSF and sent afterwards to the BCE.

• The definition of non-monetary investment funds and a list maintained by the BCL and published by the BCE.

• Statistical reporting to the BCL.

• The rules on the use of data collected.

• The quality of the transferred data.

• The respect for deadlines on submitting the reports.

• The repeal of the former circular.

The Circular 14 / 588 (only in French) is available at the following web link.

http://www.cssf.lu/fileadmin/files/Lois_reglements/Circulaires/Hors_blanchiment_terrorisme/cssf14_588.pdf

Regulatory News

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Guidelines on Duties Regarding the Charging and Use of Fees and Costs (Transparency Guidelines)

On 22 May 2014, the Board of Directors of the Swiss Funds & Asset Management Association (SFAMA) approved the Guidelines on Duties Regarding the Charging and Use of Fees and Costs (Transparency Guidelines). They will enter into force on 1 July 2014.

Objectives and scope

The aim of the Transparency Guidelines is to provide more specific detail on the duty to provide information according to art. 20 para. 1 lit. c CISA (“Swiss Collective Investment Schemes Act”). The Guidelines’ main objective is to ensure that – according to their own needs – investors are able to gain a picture of the fees and costs charged to a fund’s assets, and the use made of those fees and costs.

The Transparency Guidelines apply – in the absence of any provisions to the contrary – to “all licensees as defined in art. 13 CISA and their agents”. In addition, they also apply to “foreign funds distributed in Switzerland, their representatives, and the persons who distribute these funds in Switzerland.” However, if foreign law provides for stricter rules concerning distribution in Switzerland and these rules are contained in the pertinent fund documents, it must be ensured that Swiss investors also benefit from them. In that context, it is also important to note that the provisions of the Transparency Guidelines apply to all persons and funds only with regard to the relevant activities in or from Switzerland. Moreover, they do not cover the asset management business

Switzerland

for non-fund investors (so-called “individual asset management”) of a Swiss fund management company. Last but not least, the Transparency Guidelines are restricted to the applicable provisions of the CISA and CISO (“Swiss Collective Investment Schemes Ordinance”). Therefore, they have no influence on the relationships under private law between “a licensee /its agents and the investors”.

Overview of a selection of relevant provisions (especially regarding retrocessions and rebates)

• In respect of the use of fees and costs, the fund documents must disclose if the fees may be paid to third parties for the provision of services in connection with the performance of the fund business. However, the identity of the third party or the amounts paid to them must not be disclosed (e.g. the identity of the sub-custodian and the sub-custody fees paid to them). Moreover, the fund documents must disclose the services concerned.

• The granting of retrocessions is permitted, irrespective of the contractual relationship between the recipient of the retrocession and the investor. Nor does it matter whether the service qualifies as distribution or is not deemed to be distribution pursuant to art. 3 CISA.

• Art. 34 para. 2bis CISO in conjunction with art. 21 para. 1 CISA provides for a duty to provide information with regard to compensation for distribution. This duty is to be met by the licensees concerned that pay the retrocessions by transparently

Regulatory News

disclosing those retrocessions. This means that in the fund documents, it must be stated that retrocessions are paid, and for which services, without having to name the service providers.

• Rebates are permitted provided that (i) the financial intermediaries pay them from the fees due to them; (ii) they are granted on the basis of objective criteria; (iii) all investors who qualify on the basis of these objective criteria and demand rebates are also granted these within the same timeframe and to the same extent; and (iv) they are disclosed transparently in the fund documents.

Necessary actions

Fund management companies and SICAVs must submit fund contracts, investment regulations or sales prospectuses amended in line with these Guidelines to the supervisory authority for approval no later than 1 March 2015. As for representatives of foreign funds, they must submit fund contracts, investment regulations or sales prospectuses amended in line with the Transparency Guidelines to the supervisory authority no later than 1 June 2015. In terms of the granting of rebates, compliance with the respective provisions is only required once the corresponding amendments have been made to the fund contract, investment regulations or sales prospectus.

The complete text of the Transparency Guidelines can be found under:

https://www.sfama.ch/self-regulation/transparency

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IOSCO consults on Good Practices on Reducing Reliance on Credit Rating Agencies

In early June the International Organization of Securities Commissions (IOSCO) published a consultation report on Good Practices on Reducing Reliance on CRAs in asset management, with response due by 5 September 2014. The report is aimed at gathering the views and practices of investment managers and institutional investors, with a view to developing a set of good practices on reducing over reliance on external credit rating in the asset management space.

The report stresses the importance for asset managers to have the appropriate expertise and processes in place to assess and manage the credit risk associated with their investment decisions. Recognizing the utility of external ratings, the report mentions that they can be used as an input among others to complement a manager’s internal credit analysis and provide an independent opinion as to the quality of the portfolio constituents. However, in order to avoid the over-reliance on external ratings, the report lists some possible good practices that managers may consider when resorting to external ratings, including:

1 Investment managers make their own determinations as to the credit quality of a financial instrument before investing and throughout the holding period;

2 External credit ratings may form one element of the internal assessment process but do not constitute the sole factor supporting the credit analysis;

International

3 An internal assessment process that is commensurate with the type and proportion of debt instruments the investment manager may invest in, and a brief summary description of which is made available to investors, as appropriate;

4 An internal assessment process that is regularly updated and applied consistently;

5 Regulators could encourage investment managers to review their disclosures describing alternative sources of credit information in addition to external credit ratings;

6 Regulators could encourage investment manager to include in their credit assessments alternative (internal) sources of credit information in addition to external credit ratings;

7 Where external credit ratings are used, investment managers understand the methodologies, parameters and the basis on which the opinion of a CRA was produced, and have adequate means and expertise to identify the limitations of the methodology and assumptions used to form that opinion;

8 Regulators could encourage investment managers to disclose the use of external credit ratings and describe in an understandable way how these complement or are used with the manager’s own internal credit assessment methods;

9 Regulators could encourage investment managers, when assessing the credit quality of their counterparties or collateral not to rely solely on external credit ratings and to consider alternative quality parameters (e.g., liquidity, maturity, etc.);

10 Where an investment manager (or CIS board, as appropriate) explicitly relies on external credit ratings among others to assess the credit worthiness of specific assets, a downgrade does not automatically trigger their immediate sale. Where the manager / board conducts its own credit assessment, a downgrade may trigger a review of the appropriateness of its internal assessment. In both cases, should the manager / board decide to divest, the transaction is conducted within a timeframe that is in the best interests of the investors.

Regulatory News

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Fund News / Issue 116 / Developments in June 2014 / 11

Tax News

B-REIT: alternative to the Belgian real estate investment company (“Vastgoedbevak / SICAFI Immobilière”)

On 24 April 2014, the Belgian Parliament approved a Law concerning a new type of real estate company, namely the B-REIT or Belgian REIT.

The purpose of the law is to provide existing real estate investment companies (“Vastgoedbevaks / SICAFI Immobilières”) the opportunity to mitigate the impact resulting from the application of the AIFM (“Alternative Investment Fund Managers”) Directive. The tax rules of the B-REIT will be aligned to the ones that currently apply to Belgian real estate investment companies.

Belgium

Existing Belgian real estate investment companies can be converted in B-REITs.

The so-called AIFM Directive concerns the oversight of the management of alternative investments and subjects alternative investment funds to tight regulation. The current Belgian real estate investment companies are incorporated under the law of collective investment undertakings as investment funds (Law of 3 August 2012) and therefore qualify as alternative investment funds according to the AIFM Directive. This means that a Belgian real estate investment company – once the AIFM Directive has been transposed into Belgian law – will have to comply with additional legal obligations.

However, the Belgian legislator doubts that these additional regulations will provide added value for the existing Belgian real estate investment companies. For that reason, a law has now been adopted that makes it possible to establish an alternative type of real estate company, “B-REIT“ or “Belgian Real Estate Investment Trust”) that no longer qualifies as a collective investment undertaking.

Existing real estate investment companies can be transformed into B-REITs and will have four months to apply for licensing as a B-REIT with the FSMA. The conversion process also provides the right to exit for existing shareholders of the real estate investment company.

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Favourable tax status

The B-REIT will be able to benefit from the same tax regime as the existing real estate investment companies.

• Corporate income tax

No corporate income tax on actual profit, but an alternative, minimal basis consisting of (i) abnormal or benevolent advantages received and (ii) disallowed expenses excluding impairments and capital losses on shares.

The secret commissions tax will also apply.

• Exit tax

Existing companies which apply for and obtain the status of B-REIT will be subject to an exit tax of 16.5% (plus 3%). If no exit tax is provided for, recognition as a B-REIT would mean that deferred capital gains on the real estate could no longer be taxed. The same exit tax is applicable to (cross-border) mergers, demergers and similar transactions in which a B-REIT is involved.

What if an existing real estate investment company wishes to be recognized as a B-REIT? In these cases, the exit tax according to the law does not apply. The reason for this is that an exit tax is already levied when a company is recognized as a real estate investment company. The conversion of a real estate investment company should therefore be completely tax-neutral.

• Withholding tax on distributed dividends

Dividends distributed by B-REITs will be subject to a withholding tax of 25%, or 15% for residential B-REITs.

Dividends distributed on or after 1 January 2013 by a real estate investment company to savers / non-residents are – under certain conditions – exempt from withholding tax (Art. 106, § 7 Royal Decree / Income Tax Code). This article will be extended, through a separate Royal Decree, to B-REITs.

• Annual tax on CIUs

Oddly enough, the real estate investment trusts, although they are not explicitly collective investment undertakings, will be subject to the annual tax on collective investment undertakings.

• Stock exchange tax

Finally, the tax neutrality should – according to the Law – also be extended to the stock exchange tax. Thus, the stock exchange tax will apply to the sale and purchase of shares in B-REITs in the same way it does for real estate investment companies.

Tax News

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Fund News / Issue 116 / Developments in June 2014 / 13

Evolving Investment Management Regulation – Clarity leads to opportunity

We are pleased to announce the release of our fourth annual report on regulation in the global investment management industry: Evolving Investment Management Regulation: Clarity leads to opportunity

http://www.kpmg.com/global/en/issuesandinsights/articlespublications/evolving-investment-management-regulation/pages/2014-report-fs.aspx?utm_medium=email&utm_campaign=2014-fs-eimr&utm_source=internal&utm_content=gbl+2014+jun+19+midcolumn

In this year’s report, we focus on key areas where regulation, combined with other pressures, is forcing asset managers to make significant changes.

The key areas are:

1. Structural market change

Regulation is now upon us and is altering the way the industry operates. For example, regulation is placing pressure on the viability of pensions and there are unprecedented changes in the way that funds can be distributed.

New KPMG Report

2. Data and reporting

The shadow banking sector, which is principally investment firms, is being asked to improve its transparency. The challenge is to be able to report meaningfully, both internally and externally. With the imperative to use capital efficiently, a clearly delineated strategic approach based on analysis of existing and potential distribution channels and geographies is now a key requirement.

3. Risk governance

As regulatory complexity proliferates, so the distance lengthens between those developing and using risk systems and those making strategic business and investment decisions. High-quality risk governance decision-making facilitates forward-looking strategy.

4. Conduct culture and remuneration

Regulation is aimed at changing mindsets and the ethos of the industry. Asset managers are being encouraged to take more responsibility for how they create their products and how these products subsequently perform.

Tax News

Publications

Schweizerisches Recht der Kollektiven Kapitalanlagen

Swiss FinancialServices Newsletter: Special Edition Banking

Frontiers in Finance

EvolvingInvestmentManagementRegulation

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Frontiers in FinanceFor decision-makers in financial servicesApril 2014

Cyber crime: Insurers in the firing linePage 6

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Swiss FinancialServices Newsletter: Special Edition Investment Management

Page 14: Fund News - Issue 116 - June 2014

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

© 2014 KPMG Holding AG/SA, a Swiss corporation, is a member of the KPMG network of independent firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss legal entity. All rights reserved. Printed in Switzerland. The KPMG name and logo are registered trademarks.

Zurich

Markus SchunkPartnerT: +41 58 249 36 82 E: [email protected]

Christoph GroebliPartnerT: +41 58 249 29 76 E: [email protected]

Geneva

Yvan MermodPartnerT: +41 58 249 37 80 E: [email protected]

Lugano

Lars SchlichtingPartner, LegalT: +41 58 249 32 59 E: [email protected]

Astrid KellerPartnerT: +41 58 249 28 82 E: [email protected]

Dominik RüttimannPartnerT: +41 58 249 20 56 E: [email protected]

Pierre ZächPartnerT: +41 58 249 64 12 E: [email protected]

Pascal SprengerDirector, LegalT: +41 58 249 42 23 E: [email protected]

Grégoire WincklerPartner, TaxT: +41 58 249 34 95 E: [email protected]

Jean-Luc EparsPartner, LegalT: +41 58 249 37 49 E: [email protected]

Contacts

kpmg.ch