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By Enrique HERCE-MARCHESI, Partner, Sergio VENTI, Partner and Serena PICARIELLO, Manager at Deloitte Luxembourg
Costs, whether annual management fees or operating and administrative expenses, are critical to assessing the benefits of an investment fund. However, while the UCITS and AIFMD frameworks require that investors are not charged with undue cost, they do not unequivocally define this concept.
From mid-2020, regulators began providing harmonized guidance on assessing undue costs and related obligations, the latest of which was the Commission de Surveillance du Secteur Financier’s (CSSF) 20 October 2022 publication (hereinafter the “Feedback Report”).(1) This consisted of feedback on the European Securities and Markets Authority’s (ESMA)...
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