The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) recently updated its Frequently Asked Questions document (FAQ) on the application of AIFMD in Luxembourg. The FAQ includes helpful guidance and clarifications relating to the definition of marketing and reverse solicitation for hedge fund managers operating or marketing funds in Luxembourg. In addition, the CSSF set out further information regarding credit institutions and investment firms, depositaries and Annex IV reporting. This article summarizes the new guidance. See also “What Is the Difference Between Marketing and Reverse Solicitation Under the AIFMD?
,” Hedge Fund Law Report, Vol. 7, No. 42 (Nov. 6, 2014). For more on AIFMD, see “ESMA Opinion Highlights Issues Regarding the Functioning of the AIFMD Passport
,” Hedge Fund Law Report, Vol. 8, No. 32 (Aug. 13, 2015); and “ESMA Recommends Extension of the AIFMD Passport for Hedge Fund Managers and Funds in Certain Non-E.U. Jurisdictions
,” Hedge Fund Law Report, Vol. 8, No. 31 (Aug. 6, 2015).
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