Operational Resilience & Outsourcing
The expert group falls under the Fund Regulation & Investment Services Committee and focuses on, among other things: information security, operational resilience and outsourcing. DORA is therefore an important area of focus for this expert group.
DUFAS in action
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DUFAS response to the Market Integration and Supervision Package.
From DUFAS, we welcome the European Commission's Market Integration and Supervision Package (MISP) as an important step towards a better functioning and more integrated European capital market. The package fits within the broader ambition to strengthen savings and investment in Europe and to allow private capital flows to better contribute to economic growth, innovation and strategic investments. For asset managers operating in multiple European member states, further market integration is of great importance. Although the industry formally operates within one single market, in practice managers still experience significant differences in national regulations, supervisory practices and administrative processes. This fragmentation leads to higher costs, longer lead times and unnecessary complexity. The MISP contains proposals that seek to remove these obstacles in a targeted way.
DUFAS responds to the consultation on the Implementation Act for the amended AIFM and UCITS Directive
In April, the Ministry of Finance published the Consultation on Implementation of the Amended AIFM and UCITS Directive Act. DUFAS responded to this consultation. In our response, we have drawn attention to a number of clarifications and recommendations to align the implementation as closely as possible with the text of the European directives, the existing Dutch legislative framework and market practice.
DUFAS responds to consultation ‘Policy rule on application of SREP guidelines to managers’
In March, De Nederlandsche Bank (DNB) published a consultation on the Policy Rule on the Application of SREP Guidelines to Managers. This policy rule clarifies how DNB applies the SREP (Supervisory Review and Evaluation Process) guidelines to managers. In the Netherlands, not only investment firms but also managers of investment institutions providing MiFID services fall under the IFR/IFD regime. Based on national legislation, these managers are therefore subject to the ICARAP requirement, which authorizes DNB to apply SREP. From DUFAS, we have submitted a response to this consultation, sharing our concerns about the impact of this supervisory regime on Dutch managers.
‘Sometimes you have to shut up for a while’ – In conversation with Judith Boom, committee chair at DUFAS
