By Rémi Chevalier and Olivier Sciales, Chevalier & Sciales – I. Why Luxembourg? The establishment of the European Union’s single market has enabled the Grand Duchy of Luxembourg to become one of the leading global domiciles and service centres for both traditional and increasingly alternative investment funds and related vehicles, ranked as the world’s second-largest fund centre measured by assets under management after the United States. From the establishment of Luxembourg’s first fund in 1959 and a total of 805 at the end of 1990, the industry number has grown to 3,874 funds, comprising a total of 13,412 separate investment portfolios, at the end of May 2012.
The fund industry has benefited from the open-arms welcome of the Luxembourg authorities toward foreign businesses, capital and investment, as well as the country’s location in the heart of western Europe, close to the continent’s principal investment fund markets, its highly qualified and polyglot workforce, and its political, economic and social stability. The grand duchy’s competitiveness has been strengthened by a business-friendly tax regime favouring the establishment of funds, and a comprehensive legislative framework designed for both traditional and alternative investments.
The authorities and industry representative pay close attention to changes in the regional and worldwide operating and market environment for investment funds and the country’s legislation has been refined and updated in a timely manner, coupled with the practice of becoming one of the first member states to adopt EU directives into national law. Today, despite the unfavourable global economic climate and continuing uncertainty over the creditworthiness of both private and sovereign debtors, Luxembourg has not only maintained its position as an international fund distribution hub but has seen the net assets under management of domiciled funds reach EUR2.212trn (about USD2.79trn) in May 2012.
II. Legal and regulatory framework
The law of February 13, 2007 established Specialised Investment Funds as a vehicle designed for alternative investments and other funds aimed at sophisticated investors. It was amended by the law of March 26, 2012, to take account of new and impending EU legislation including the Ucits IV directive and the Alternative Investment Fund Managers Directive, which will come into effect on July 22, 2013, as well as the increased experience of Luxembourg’s financial regulator, the Financial Sector Supervisory Commission (usually known by its French acronym, CSSF), in overseeing alternative funds. The revised SIF law came into force on April 1, 2012.
The law brings the SIF legislation into line with AIFM Directive rules in areas including delegation, risk management and the handling of conflicts of interest. In parallel with the December 2010 funds legislation that transposed the Ucits IV directive into Luxembourg law, it allows sub-funds of a SIF umbrella structure to invest in other compartments of the same structure in the same way that Ucits funds can do.
Article 5 of the revised law abolishes a peculiarity of the SIF regime that allowed fund promoters to wait until up to a month after the launch of a fund to submit it to the CSSF for approval. Henceforth funds must be authorised by the regulator before they can be launched, like funds created under the 2010 legislation. In practice, this provision was rarely used because of the risks of having to revise a structure after it had been launched.
The legislation is relatively short, consisting of just 18 articles. The first article states that the activity of management of a SIF must comprise at least management of the investment portfolio, excluding passive funds that seek to create value solely by the long-term holding of assets and creates a distinction between SIFs and private wealth management companies created under Luxembourg’s law of May 11, 2007, but it does not exclude private equity or real estate funds.
Article 3 allows SIFs created as open-ended investment companies (Sicavs) to benefit from measures in the 2010 law under which fund articles of association drawn up in English no longer need to be translated into French or German, nor do they need to send shareholders physical (as opposed to electronic) copies of their annual reports except on request. It also sets rules for voting rights and what constitute a quorum at shareholder AGMs.
The legislation now requires SIFs to put in place systems to detect, measure, manage and monitor the investment risk of its individual positions and their contribution to the portfolio’s overall risk profile. SIFs must also be structured and organised to minimise the risk of conflicts of interest, and draw up rules to manage any conflicts that do arise without causing harm to investors.
Article 7 sets down that where SIFs delegate tasks and functions to third-party providers, the CSSF must be informed in advance and delegation should not affect oversight of the fund. Individuals or legal entities to which portfolio management is delegated must be appropriately authorised or licensed and regulated, except by express permission from the CSSF
A SIF’s managers must be able to determine that the delegated provider is qualified and capable, and they must retain ultimate control over the fund’s activities and the ability to revoke the delegation. Delegation should not create conflicts of interest – so, for instance, investment management may not be delegated to the fund’s custodian – and the delegation of functions must be revealed in the fund’s offering documents.
Article 13 states that funds are not prohibited from deviating from their investment policy for the purposes of liquidity management, hedging or efficient portfolio management. Article 15 allows the CSSF to withdraw authorisation for one or more sub-funds of a SIF while maintaining the authorisation for other sub-funds of the same structure.
Article 16 of the law follows the 2010 legislation in allowing one sub-fund of a SIF to invest in another. This article clarifies that the rules regarding a company’s investment in its own shares set out in Luxembourg’s 1915 company law do not apply to SIFs. Sub-funds of the same SIF may not cross-invest in each other, and voting rights of shares held by one sub-fund in another are suspended.
Article 17 stipulates that SIFs established before the date of entry into force of the amendment law, April 1, 2012, have a transitional period up to June 30, 2013 to comply with the new rules on the delegation of functions (Article 42ter).
The law of December 17, 2010 incorporated into Luxembourg’s legislation the Ucits IV directive, the latest iteration of the EU’s regime for cross-border distribution of investment funds to retail investors, dating back to 1985. The law differentiates between Undertakings For Collective Investment In Transferable Securities (Ucits, regulated largely by Part I of the 2010 law) and other Undertakings For Collective Investment (UCIs or Part II funds, so called after Part II of the 2010 law which governs them)
Other recent regulatory developments include the issue of CSSF Circular 11/512 presenting the main regulatory changes in risk management following the publication of CSSF Regulation 10-4 and clarifications by the European Securities and Markets Authority (Esma) as well as the CSSF Circular 11/509 regarding the new notification procedure for Luxembourg Ucits seeking to market their shares or units in other EU member states, and for Ucits from other member states seeking to market in the grand duchy.
Luxembourg funds, both Ucits and SIFs, can benefit from a fast-track procedure under which in principle (although this is not guaranteed) the CSSF aims to transmit its comments and observations to the applicant within as little as 10 working days. In practice authorisation is likely to take a minimum of three weeks for SIFs and four weeks for Ucits, and in some cases longer. The CSSF provides a five-step approval process for the establishment of a Luxembourg fund:
1. Initial submission of the questionnaire requesting authorisation
An application file consisting of the completed application questionnaire and appended documents, should be submitted together by electronic means, through the CSSF’s e-file programme or e-mail, once all constituents of the project are completely settled.
2. Acknowledgement of receipt of the application file
The CSSF will acknowledge receipt of the application file within two working days and will inform the applicant about the staff member in charge of examining the application through the e-file programme or e-mail.
3. Transmission of CSSF feedback and further requests of information
The CSSF aims (but does not guarantee) to contact the applicant or a contact person designated in the questionnaire with feedback within 10 working days following receipt of the file. The applicant may be asked for further information and/or supporting documents, or to explain specific aspects of the application.
4. Completion of examination phase and invitation to submit final version of documents
The CSSF will inform the applicant when the examination phase of the application is completed. From this point, applicants may not change the scope of the application or alter the final versions of the constitutive documents on the basis of which the examination has been completed, otherwise the examination will have to begin again at stage 2. Confirmation of a satisfactory completion of the examination phase mean the applicant may submit the final clean version of any compulsory documents required to finalise the approval process of the fund.
5. Entry of the fund on the official list
Formal accreditation and entry on the official list is contingent on the submission of all required documents in a finalised form, a prospectus under the terms of Circular CSSF 08/371, and the management regulations, articles of incorporation and agreements in signed form. Upon satisfactory receipt of the prospectus and other required documents, the CSSF will register the fund on the official list. The regulator will also will issue official accreditation letters, related attestations and identification codes, register the documentation and return a visa-stamped version of the full prospectus within five working days following receipt of the required documents.
Luxembourg investment funds are divided into three categories:
UCIs or Part II funds (582 as of the end of May 2012).
Ucits (1,859 in May 2012).
SIFs (1,433 in May 2012)
Ucits are designed for retail investors, and benefit from the so-called EU ‘passport’ that allows them to be marketed freely throughout all 27 EU member states as well as other countries belonging to the European Economic Area with a minimum of notification requirements. Transferable securities are defined in Article 1 of the 2010 law as shares in companies or other equivalent securities, bonds and other forms of securitised debt, and any other negotiable securities, including certain types of derivative instrument, that carry the right to acquire transferable securities by subscription or exchange.
Four categories of fund investing in transferable securities fall outside Part I of the 2010 law:
Funds that raise capital without promoting the sale of their shares or units to the public within the EU.
Funds whose management regulations or constitutional documents stipulate that they may be sold only to the public in countries that are not EU member states.
Categories of funds determined by the Luxembourg financial regulator, the CSSF, for which the investment policy rules laid down in Chapter 5 of the 2010 law are inappropriate in view of their investment and borrowing policies.
ii) Part II funds
By contrast, UCIs established under Part II of the 2010 law may only market their shares or units in other EU countries or elsewhere if they comply with the individual conditions laid down by the authorities in the country concerned. The criterion determining whether a fund is subject to Part I or Part II of the 2010 law is its planned investment objective; Part I of the 2010 law applies only to funds whose the sole objective is investment in transferable securities, whereas a Part II fund may invest in other types of asset, making them suitable as the legal form for the establishment of alternative investment vehicles including hedge, venture capital and real estate funds.
The SIF law of 2007 replaced the legal framework previously applicable to institutional funds through a law of 1991 by establishing a statutory regime specifically designed for investment funds aimed at sophisticated investors, and it was amended by the law of March 26, 2012. The SIF is a lightly regulated and tax-efficient fund offering promoters an onshore alternative to traditional offshore jurisdictions such as the Cayman Islands or British Virgin Islands when deciding on the jurisdiction in which to set up a fund and type of vehicle to use. Like Part II funds, investment funds created under the SIF law are subject to the individual distribution rules of each country where they are marketed
iv) Regulatory body
The CSSF authorises and oversees all Luxembourg registered funds. Its annual regulatory fees for funds under the 2010 law and SIFs are EUR2,650 for a single compartment fund and EUR5,000 for a multiple compartment fund.
v) Future regulatory changes
Non-Ucits funds established in Luxembourg and other EU member states, as well as managers domiciled within EU countries, will be subject from July 22, 2013 to the provisions of the Directive on Alternative Investment Fund Managers, which will provide a harmonised regulatory framework for the distribution across the EU of funds aimed at sophisticated investors.
The directive was formally agreed on June 8, 2011 and it formally entered into force on July 21, 2011, but member states have two years to transpose its measures into national law. Detailed ‘Level 2’ implementation measures are expected to be enacted in the form of a regulation from the European Commission in the second half of 2012. The regulation, which will have direct application in member states and will not have to be adopted into national law, is based on advice from the European Securities and Markets Authority (Esma), delivered to the Commission on November 16, 2011 following consultation with industry members and representative organisations. The Commission is not obliged to follow all of Esma’s recommendations and is not expected to do so.
Luxembourg is expected to pass legislation transposing the AIFM Directive into national law before the end of 2012. This may be accompanied by other legislation affecting the fund industry including the establishment of a partnership structure effectively replicating limited liability partnerships in common law jurisdictions.
A draft text of the next iteration of the Ucits directive, dubbed Ucits V, was published by the European Commission at the beginning of July 2012. Its main purpose is to bring the Ucits rules on remuneration of fund managers and depositary requirements into line with those enacted in the AIFM Directive.
III. Constitution of a fund and legal structures
Investment funds may take the form of an open-ended investment company (known as a Sicav after its French acronym), of which there were 1,909 at the end of May 2012, a closed-ended investment company or Sicaf, of which there were 31 in May 2012, or a common contractual fund (FCP) with a management company (1,929 in May 2012). Any of these entities may be established as an ‘umbrella’ structure with multiple compartments or sub-funds with different investment policies. In this case each compartment is treated as a segregated entity whose assets belong to and may be claimed by only investors in that particular sub-fund; creditors of or investor in other sub-funds have no claim against the assets.
i) Sicavs and Sicafs
A Sicav is a open-ended investment company whose capital is always equal to its net assets, and for which no formalities are required for increases and reductions in capital through investments in or redemptions of its shares at investors’ request at a price equal to the net asset value per share. By contrast, a Sicaf is a closed-ended investment company whose investors do not have the right to redeem their shares at their request before any expiry of the fund’s term.
An FCP is a common contractual fund, the liability of whose joint owners is limited to the amount they have invested. It should be noted that an FCP has no legal personality and therefore must be managed by a Luxembourg management company, whereas a Sicav or Sicaf can be managed by its board of directors. Ucits in the form of FCPs are managed by management companies under the conditions laid down in Chapter 15 of the 2010 law, whereas Chapter 16 of the 2010 law lays down the conditions under which management companies manage Part II funds.
iii) Choosing a legal structure
The choice of whether to create a fund as an FCP or as an investment company (Sicav or Sicaf) is mainly based on tax considerations. An FCP is tax transparent, a concept guaranteed in the Luxembourg tax legislation. Marketing and operational considerations are also relevant to the choice of this vehicle since a Luxembourg-domiciled FCP benefits from the high service standards provided by management companies in the grand duchy.
The cultural background of different countries appears to influence the choice of promoters whether to create a fund as an FCP or as an investment company. For example, FCPs are traditionally widely used in Germany, while in France investors are more familiar with investment in Sicavs.
iv) Fund establishment expenses
According to the latest regulation regarding regulatory charges, issued on April 1, 2010, formation expenses comprise a fixed capital duty amounting to EUR75 for all funds, notary’s fees, legal fees, and a CSSF filing duty of EUR2,650 for a single-portfolio fund or EUR5,000 for an umbrella fund, whether the fund is established under the law of December 17, 2010 or is a Sicar or SIF. The formation expenses may also comprise a Stock Exchange visa fee of EUR1,250 for a Luxembourg or EU fund, or EUR2,500 for a non-EU fund.
v) Minimum capitalisation
The minimum capitalisation of EUR1.25m required under both the 2007 and 2010 laws must be reached within 12 months following approval by the CSSF in the case of a SIF, compared with six months for a fund set up under the 2010 law.
vi) Regulatory control
Funds set up as SIFs now require regulatory approval prior to incorporation, in the same way as funds set up under the 2010 law. While funds established under the SIF law are not required to have a promoter, the SIF’s directors are subject to approval by the CSSF; they must enjoy a good reputation and be able to demonstrate the experience necessary to manage the type of alternative investment fund in question. Article 5 of the 2012 law says the persons responsible for management of the SIF’s investment portfolio, and any changes, must be notified to the CSSF, which must certify that they are of good reputation and have the experience necessary to manage the type of alternative investment fund in question.
In complying with the establishment requirements, fund promoters can benefit from the overall financial infrastructure in Luxembourg, which included 143 banks as of the end of May 2012.
IV. Investors’ eligibility
Investment funds set up under the 2010 law are authorised for public distribution and there is no restriction on the eligibility of investors, whereas by contrast the SIF law incorporates restrictions on qualifying investors. SIFs are reserved for “well-informed investors” able to understand and assess the risks associated with investments in such a fund. Well-informed investors are defined as institutional investors, professional investors, or any other investors who have declared in writing that they are well-informed investors and either invest a minimum of EUR125,000 or are certified by a bank, investment firm or management company as having the appropriate expertise, experience and knowledge to understand investment in the fund adequately. Article 2 of the 2012 law requires SIFs to have in place procedures to verify that its investors qualify as sophisticated rather than retail clients.
V. Investment restrictions
Within the broad principle of risk spreading, different types of fund are subject to varying rules governing the scope of their investment policy. The rules are significantly restrictive in the case of Ucits, lighter for Part II funds and substantially lighter for SIFs.
The 2010 law imposes a range of restrictions upon investments by Ucits that have been clarified by recent statements from the regulator:
The grand-ducal regulation of February 8, 2008 clarifies the notion of Ucits as provided in the 2002 and 2010 laws, in light of the Commission Directive 2007/16/EC.
Circular CSSF 08/339 (as amended by Circular 08/380) implements the guidelines of the Committee of European Securities Regulators (Cesr, which became Esma on January 1, 2011) in relation to eligible assets for investment by Ucits, and provides additional clarifications relating to the eligible asset rules of the successive Ucits directives, which has been expanded to include not only transferable securities and money market instruments but bank deposits, funds of funds, derivatives and funds tracking recognised financial indices.
ii) Non-Ucits Part II Funds
While there are no restrictions on eligible assets in which a Part II fund may invest, its investment policy is subject to approval by the CSSF, and certain rules are laid down in Circular IML 91/75 (as amended by Circular CSSF 05/177), while others are specifically applicable to funds pursuing alternative investment strategies. These rules are laid down in Circular CSSF 02/80, which states that:
Aggregate commitments in terms of short selling may not exceed 50 per cent of assets, and no more than 10 per cent of securities of the same type issued by the same issuer may be sold short.
Borrowings must not exceed 200 per cent of net assets.
Counterparty risk, defined as the difference between the value of assets given as guarantee and the amount borrowed, may not represent more than 20 per cent of the fund’s assets per lender.
Specialised investment funds set up under the law of February 13, 2007, as amended by the law of March 26, 2012, are not required to comply with any detailed investment restrictions or leverage rules. The legislation merely states that a SIF should apply the principle of risk diversification under which the collective investment of funds must be made in assets “in order to spread the investment risks”. The CSSF clarified in Circular 07/309 that:
A SIF may not invest more than 30 per cent of its assets or commitments in securities of the same type issued by the same issuer.
Short sales may not result in the SIF holding a short position in securities of the same type issued by the same issuer representing more than 30 per cent of its assets.
When using derivatives, the SIF must ensure a similar level of risk-spreading via appropriate diversification of the underlying assets.
However, the CSSF may, if it deems the circumstances appropriate, grant exemptions to these rules on a case-by-case basis.
VI. Reporting and audit requirements
Funds are obliged to issue a prospectus containing a presentation as well as economic and commercial information on the fund and its management company. The law of July 10, 2005 on prospectuses for securities specified that closed-ended funds falling outside Part I of Luxembourg’s fund legislation were exempt from the obligation to publish a full prospectus, although such funds were still obliged to publish a simplified prospectus. This was also obligatory for Ucits funds up to July 1, 2011, when the law of 2010 replaced the simplified prospectus for new funds by the Key Investor Information Document. Under the 2010 law, the prospectus must include the information necessary for investors to make an informed judgment about the proposed investment in the fund, and especially of the risks involved; it must be updated whenever necessary for this purpose and at least annually.
Under Article 12 of the 2012 law, the CSSF’s approval is required for any substantial change made to the SIF’s offering documents, such as the name of the fund or of sub-funds, the replacement of the custodian, administrator, auditor or manager, the creation of new sub-funds or a significant change in investment policy.
Ucits funds must comply with the Esma guidelines 10-788 of July 28, 2010, which require inclusion in the prospectus of information relating to risk management. This includes the method used to calculate global exposure by differentiating between the commitment approach, relative Value at Risk approach and absolute VaR approach; for Ucits adopting the VaR approach, the expected level of leverage and any possibility of higher leverage levels; and information on the reference portfolio when Ucits use the relative VaR approach.
ii) Issuing document
As part of the lighter regulatory regime than that for Part II funds governed by the 2010 law, SIFs are required only to produce an ‘issuing document’ comprising the information necessary for investors to make an informed judgment investment in the fund, although the 2007 law does not specify any minimum content. The issuing documents and any subsequent changes to it must be communicated to the CSSF.
iii) Financial statement
Luxembourg funds (or their management companies in the case of common contractual funds) are required to publish at least an annual report and, in the case of investment companies and FCPs governed by the 2010 law, also a half-yearly report covering the first six months of the fund’s financial year. The annual report must include audited accounts and a report on the fund’s business, as well as any other information necessary for investors to make an informed judgement about the fund. The audit must be conducted by an authorised independent auditor who is qualified and a member of the Luxembourg Institute of Auditors (IRE). The auditor must report promptly to the CSSF if any information provided to investors does not truthfully describe the financial situation of the fund, or if the auditor becomes aware during the audit that any fact or decision is liable to constitute a material breach of the law or regulations, or to affect the ongoing functioning of the fund.
It should be noted that unlike a fund established under the 2010 law, a SIF is not obliged to disclose details of its portfolio as part of the information necessary for investors to make an informed judgment about the fund, nor is it required to publish the net asset value per share of the fund, as is the case for Ucits and Part II funds
iv) Key Investor Information Document
Until July 2011 Ucits funds were also required to produce a simplified prospectus, providing a summary of the main prospectus. Under the Ucits IV directive, implemented into Luxembourg’s domestic legislation by the law of December 17, 2010, this is replaced by the Key Investor Information Document (KIID for short), designed to provide full but concise information on the fund’s main features, written in plain, non-technical language and produced in a standard format, usually on two A4 pages.
Designed to provide investors with a more easily understandable picture of the fund’s activities than was provided by the simplified prospectus, the KIID seeks to describe in straightforward terms the fund’s investment strategy, the risks involved, the service providers used by the fund, the charges levied against the fund’s assets for investment management and other services, and its recent performance where this is applicable. A separate KIID must be produced for each Ucits fund or sub-fund, and may also be produced for different classes of shares or units in the same fund of sub-fund where there may be significant differences in performance between them. The KIID should enable investors to make an informed choice about investing in a fund without reading the full prospectus, and it should enable them to compare one fund with another easily.
Since July 1, 2012, all Ucits funds are required to have a KIID. Any significant changes to the fund, such as in its risk/reward profile or its management, require the issue of an amended KIID, and it must be updated at the end of each year. It must be published in at least one of the official languages, or another language approved by the local regulator, of any EU country in which the fund is to be marketed.
VII. Taxation of funds
Luxembourg Ucits, Part II funds and SIFs do not pay income and capital gains taxes in the grand duchy, nor is stamp duty payable on share issues or transfers.
There is a fixed capital duty of EUR75 to be paid upon incorporation. In addition, some funds are also subject to an annual subscription tax. Under the SIF law this annual subscription tax is levied at 0.01 per cent of the fund’s net assets, compared with a standard rate 0.05 per cent for funds under the 2010 law. However, the rate is 0.01 per cent for funds whose exclusive policy is investment in money market instruments or bank deposits. Other funds, such as certain institutional cash funds and pension pooling funds, are exempted from the subscription tax, no matter under which law they are set up. The 2010 law extended or confirmed this exemption for exchange-traded funds and funds whose primary aim is investment in microfinance institutions. It should be noted that investors may invest in a SIF by means of equity or debt in order to benefit from effective tax optimisation, and that SIFs do not have to respect any particular debt-equity ratio.
Luxembourg has signed double taxation treaties with 64 countries, and 21 others are under negotiation or awaiting approval from Luxembourg’s parliament or the legislature of the other country. These agreements seek to eliminate or reduce withholding taxes on foreign income or capital gains. However, only 36 of these treaties are applicable to Sicavs, whether in the form of a Ucits, Part II fund or SIF.
VIII. Stock Exchange Listing
Luxembourg funds in the form of Ucits, Part II funds and SIFs as well as foreign funds may be listed on the Luxembourg Stock Exchange. Various conditions must be met by foreign funds seeking a listing on the exchange, notably that the fund promoter is of good reputation and has adequate and appropriate professional experience.
The annual Luxembourg Stock Exchange listing fee for Luxembourg and EU funds is currently EUR1,875 for a first line of quotation, EUR1,250 for a second, EUR875 for a third and EUR500 for a fourth and any additional lines of quotation. The fees for non-EU funds are EUR2,500 for a first line of quotation, EUR1,875 for a second, EUR1,250 for a third and EUR875 for a fourth and any subsequent listings.
The Luxembourg investment fund industry, as part of a leading international financial centre, is now a recognised label for funds throughout Europe and in other parts of the world, including East Asia, the Middle East and South America. The country continues to benefit from the political consensus in favour of maintaining the competitiveness of the fund industry and the financial sector as a whole, reflected in the proactive approach of the authorities to the adoption of EU legislation and the regular revision of national fund regimes to take into account the needs and preferences of global standard-setters, investment managers, fund service providers and investors. These efforts have contributed significantly to the creation of a stable and protective environment for the fund industry and the strengthening to Luxembourg’s global reputation and market position.
The pragmatism of the Luxembourg authorities is also reflected in the regulatory approach of the CSSF to industry members, its readiness to engage in dialogue with market participants, and its careful calibration of the appropriate balance of the interests between industry members and investors, especially important in view of the ongoing global market turbulence that continues to impact the fund industry.
Luxembourg’s long-standing dominance in Europe’s cross-border retail fund industry has provided it with broad awareness of the need for industry transparency and effective protection of investors, a feature that has helped to consolidate its market position during periods of turbulence and instability.
The next challenge is the EU’s Alternative Investment Fund Managers Directive, which was finalised in June 2011 and will come into effect on July 22 next year. The directive will introduce a harmonised regulatory framework for alternative fund managers seeking to market products within the EU that will include greater disclosure levels than the industry has typically adhered to in the past, and that will give Luxembourg fresh opportunities to meet the needs of managers and investors.
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