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Practice paper

Developments in relation to risk management for European investment funds

Henning Schwabe and Mohamed Ed-Diaz
Journal of Risk Management in Financial Institutions, 13 (4), 357-373 (2020)
https://doi.org/10.69554/SKOJ9905

Abstract

This paper gives an overview of the recent developments in liquidity risk management for investment funds through the example of measures applicable to funds domiciled in Luxembourg. The paper first outlines the current context regarding risk management, with a focus on liquidity risk management. It then presents risk-management requirements to the undertakings for collective investment in transferable securities (UCITS) and alternative funds. Next, the paper discusses liquidity risk management with consideration of its legal definition and management practices and the need to address such risks at each stage of the life of the fund (design stage, postlaunch stage and stress testing through the funds’ activity). This study is based on the frame set by EU (European Union) law provisions, such as the UCITS Directive or The Alternative Investment Fund Managers Directive, and national Luxembourg legislation, including Luxembourg’s regulatory implementation of international standards such as The International Organization of Securities Commissions (IOSCO) Recommendations on liquidity risk management. This paper further outlines the important role of the Luxembourg regulator, the Commission de Surveillance du Secteur Financier (the CSSF), which has been proactively developing at a very early stage a strong administrative practice to ensure that liquidity risk-management processes meet the required standards in order to promote a sound and prudent fund financial situation. Therefore, the authors recommend strongly that the risk-management system of each relevant market player be checked for compatibility with the IOSCO recommendations and, where appropriate, with the CSSF Circular 19/733. They also stress the importance of adequate stress testing on risks related to liquidity to prepare for volatile times such as the current situation with the global pandemic coronavirus disease-2019 (COVID-19).

Keywords: investment fund; liquidity risk management; UCITS; CSSF; alternative funds; COVID-19

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Author's Biography

Henning Schwabe is a Partner at Arendt & Medernach and is specialised in investment fund law involving complex investment strategies, derivatives and risk management. He is Chairman of the European Market Infrastructure Regulation (EMIR)/over-the-counter Derivatives working group of the Association of the Luxembourg Fund Industry and Board Member of the Luxembourg Association for Risk Management as well as a regular speaker at international seminars and conferences.

Mohamed Ed-Diaz is a Manager at Arendt Regulatory & Consulting, in charge of Risk-Management Services Delivery. With more than nine years of experience and risk-management expertise in the financial markets and in the investment funds sector, he developed a wide set of skills: at the market risk department of the Banque Internationale in Luxembourg, as a risk analyst within an undertakings for collective investment in transferable securities management company and as an alternative investment fund manager.

Citation

Schwabe, Henning and Ed-Diaz, Mohamed (2020, September 1). Developments in relation to risk management for European investment funds. In the Journal of Risk Management in Financial Institutions, Volume 13, Issue 4. https://doi.org/10.69554/SKOJ9905.

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cover image, Journal of Risk Management in Financial Institutions
Journal of Risk Management in Financial Institutions
Volume 13 / Issue 4
© Henry Stewart
Publications LLP

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