Update of the CSSF FAQ providing clarifications for UCITS in relation to shortened settlement cycle in the United States
The CSSF has published today an update of the CSSF FAQ regarding Circular CSSF 02/77 (which will be replaced by Circular CSSF 24/856 as of 1 January 2025) as well as of the CSSF FAQ on the Law of 17 December 2010.
In the context of the move of the standard settlement cycle from T+2 to T+1 amongst others in the United States, UCITS may be facing operational challenges, including from an investment compliance perspective, resulting notably from timing gaps between the settlement cycles on the asset side (securities transactions) and on the liability side (subscriptions/redemptions).
The updates of both FAQs aim at clarifying the expectations of the CSSF in relation to investment compliance.
The clarifications have been included in the following FAQs:
- FAQ regarding Circular CSSF 02/77 (new question 4.a and modification of question 4 that has become question 4.b)
- FAQ concerning the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment (modification of question 1.14).