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By Dr. Sebastiaan NIELS HOOGHIEMSTRA* and Anne-Sophie MORVAN**
Banking lived a little revolution in 2019 when it was forced by the Payment Services Directive (EU) 2015/2366 (“PSD2”) to open up to third party providers through APIs. A similar revolution is introduced by the recently released Proposal for a Regulation on a Framework for Financial Data Access (FiDAR) for a larger scope of financial institutions, including investment firms, managers of alternative investment fund managers (“AIFMs”) and management companies (“UCITS ManCos”) (together, “Financial Institutions”). This contribution aims at providing a brief overview of the impact of FiDAR on the (Luxembourg) investment fund industry.
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