The CSSF has updated question 7 to include information about changes made for the reporting Early Warning on large redemptions (UCITS). The following has been added to the answer:

The reporting Early Warning on large redemptions (UCITS), which is only relevant for a limited number of UCITS that have, in the past, been contacted directly by the CSSF, is suspended until further notice following the introduction of the “IFM Notification – Fund issues/Large redemptions.

QUESTION 7. Can the deadlines for the reports to be submitted by UCIs, SIFs, SICARs, investment fund managers, pension funds and securitisation undertakings be extended?

The deadlines for the documents listed below may be extended provided that the CSSF is informed thereof. The communication to the CSSF must only be made by email and exclusively to the address opc@cssf.lu. Nevertheless, submission on time is encouraged, where the submission can be made within the usual time limits without compromising the quality of the reporting and in line with the health rules to contain the spread of Covid-19.

  • The annual reporting O 4.1./ O.4.2 (UCI) on the basis of Circular IML 97/136 to be submitted to the CSSF within four months (for UCITS)/six months (for non-UCITS) as from the reference date – this deadline may be extended until 30 June 2020;
  • The monthly reporting O 1.2. (UCIs with formal guarantee) to be submitted to the CSSF within 10 days following the end of the month – this deadline may be extended until 30 June 2020; –
  • The quarterly reporting G.2.1. (SIAG/FIAAG) on the basis of Circular CSSF 18/698 to be submitted to the CSSF within 20 calendar days following the end of the preceding month – this deadline may be extended until 31 August 2020;
  • The quarterly reporting G.2.1. (management companies subject to Chapters 15 and 16, AIFMs) on the basis of Circular CSSF 15/633 to be submitted to the CSSF within 20 calendar days following the end of the preceding month – this deadline may be extended to 40 calendar days following the end of the preceding month;
  • The management letter to be communicated to the CSSF on the basis of Circulars IML 91/75 and CSSF 19/708 within four months (for UCITS)/six months (for non-UCITS) after the closing date – an additional period of three months may be granted;
  • As regards the UCI long form reports to be communicated to the CSSF on the basis of Circular CSSF 02/81 within four months (for UCITS)/six months (for non-UCITS) after the closing date, a period of four months after the ordinary general meeting for SICAVs, as stated in the official CSSF communiqué of 25 March 2020 – “Long form reports”, or a period of four months after the regulatory deadline for FCPs, may be granted;
  • The semi-annual reporting K3.1 (SICAR) on the basis of Circular CSSF 08/376 to be submitted within 45 calendar days following the reference date – this reporting may be suspended until further notice;
  • The semi-annual reporting URR (UCITS Risk Reporting) to be submitted within 45 calendar days following the reference date – the CSSF will notify of a possible postponement in due time;
  • The closing documents to be provided annually by IFMs pursuant to sub-points (3) to (15) of point (3) of Annex 2 to Circular CSSF 18/698 to be submitted within five months following the closing date of the IFM’s financial year – for the IFMs which closed their financial year on 31/12/2019, this deadline may be extended until 31/08/2020; for the IFMs whose financial year closed after 31/12/2019, this deadline may also be extended by three months;
  • The management letter to be submitted by IFMs within the month following the ordinary general meeting that approved the annual accounts and at the latest seven months after the closing date of the IFM’s financial year – an additional period of one month may be granted;
  • The quarterly reporting of authorised AIFMs with the list of managed AIFs – this deadline is extended until 30 June 2020;
  • The quarterly reporting to be submitted by pension funds within 20 calendar days following the end of the preceding quarter – this deadline may be extended until 20 July 2020;
  • The management letter to be submitted by pension funds within six months following the closing date of the financial year – this deadline is extended until 31 August 2020;
  • The actuarial report to be submitted by pension funds within six months following the closing date of the financial year – this deadline may be extended until 30 September 2020;
  • The management letter to be submitted by authorised securitisation undertakings within six months following the closing date of the financial year – an additional period of two months may be granted;
  • The quarterly reporting VaR & Leverage (UCITS) – this reporting, which is only relevant for a limited number of UCITS that have, in the past, been contacted directly by the CSSF, may be suspended until further notice by sending a notification to the address opc@cssf.lu;
  • The monthly reporting Money Market Funds (UCITS/AIF) – this reporting, which is only relevant for a limited number of UCITS/AIFs that have, in the past, been contacted directly by the CSSF, may be suspended until further notice by sending a notification to the address opc@cssf.lu. This reporting must not be confused with the MMF reporting established by Article 37 of MMF Regulation 2017/1131;
  • “The reporting Early Warning on large redemptions (UCITS), which is only relevant for a limited number of UCITS that have, in the past, been contacted directly by the CSSF, is suspended until further notice following the introduction of the “IFM Notification – Fund issues/Large redemptions.”

As announced by ESMA in a statement dated 31 March 2020, the submission of reporting files to National Competent Authorities (NCAs) under Article 37 of the Money Market Funds Regulation has been postponed to September 2020. ESMA will publish shortly an amended XML schema (version 1.1) and reporting instructions on its website. The reference period for the first reporting remains however Q1 2020.

Based on this statement and by way of derogation from Circular CSSF 20/736, managers of Luxembourg domiciled MMFs may therefore postpone the submission of the quarterly reportings for Q1 and Q2 2020 to September 2020.

Nevertheless, as the CSSF will implement the amended XML schema as soon as possible, submission of the reportings before the September deadline is encouraged. The CSSF will issue a separate communication once reporting entities may use the amended XML schema to provide the reporting files.