Publication of Circular CSSF 22/821 on the revised long form report for credit institutions

The CSSF published today Circular CSSF 22/821 revising the framework of the long form report for credit institutions and repealing Circular CSSF 01/27. The circular is the result of a thorough reconsideration of the objective, scope and content of the current long form report, which is a key component of CSSF’s supervision. The revision ensures that the long form report remains in line with regulatory developments and with the supervisor’s main points of focus. The framework was redesigned in a way to minimise supervisory burden. Content-wise this resulted for instance in eliminating redundancies in credit institutions’ reporting obligations while, with respect to form, the new long form report turns fully digital which allows efficient processing in line with the CSSF’s digital strategy.

The revised long form report framework comprises the following four annual deliverables, where items 3 and 4 remain as is:

1. A self-assessment questionnaire (SAQ) to be filled in by credit institutions;
2. Agreed Upon Procedure (AUP) report(s) to be established by the réviseur d’entreprises agréé (REA);
3. The separate report on the protection of financial instruments and funds belonging to clients as required under Article 7 of the Grand-ducal Regulation of 30 May 2018 to be established by the REA;
4. The separate report covering AML/CFT further to CSSF Regulation N° 12-02 to be established by the REA.

The completion and submission of the deliverables are to be done through the dedicated online portal of the CSSF (“eDesk”). The online forms will be accessible on the portal at the beginning of 2023. In the meantime, Excel versions of the SAQ and AUP templates are available for consultation only in the “Related documents” section under Circular CSSF 22/821 on the CSSF website.

Further impacts of the revision

Circular CSSF 01/27 also contains provisions on the scope of the statutory audit mandate as well as on the content of the reports and written comments issued by the REA in the framework of its audit of the annual accounting documents. These provisions remain relevant, will be updated and published in a separate circular in the coming weeks.

In addition, the following circulars need to be updated after the publication of Circular CSSF 22/821, namely Circular CSSF 07/325 (“Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services”) and Circular CSSF 19/731 (“Documents to be submitted to the CSSF and to the European Central Bank on an annual basis”).

Dedicated webinar

The ABBL will host a webinar to inform its members on the changes introduced by Circular CSSF 22/821. This webinar will bring together a panel of representatives from the ABBL and the CSSF to present Circular CSSF 22/821 and to highlight the main evolutions brought by the revision of the long form report. The presentation will be followed by a dedicated Q&As session addressing the questions of the industry.

The webinar is open to ABBL’s members and will take place on Thursday, 10 November 2022 from 10.30 a.m. to 11.45 a.m. Please note that the webinar will be recorded and will be available on the ABBL and the CSSF’s websites after the event.