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 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
DUFAS responds to consultation on Active Account Requirement under EMIR
In November, ESMA published a Discussion Paper on the conditions of the Active Account Requirement (AAR) under EMIR 3. From DUFAS, we responded to this paper expressing support that compliance with the AAR should not create excessive additional costs. At the same time, we express some concerns.
