Changes to CIU authorisation and declaration processes

The ROSA extranet, which is intended to replace the current GECO extranet, will further digitalise interactions between the AMF and investment management companies. Launched for portfolio management companies in early 2021, this tool will be operational for collective investment undertakings in early 2024. With this in mind, the AMF is updating its guidance.

Further digital interactions with the AMF

The AMF is committed to increasing its agility and further digitalising its processes, both internally and with professionals. Against this backdrop, the ROSA extranet, which was launched for investment management companies in early 2021, will be officially launched for collective investment undertakings (CIUs) in early 2024, replacing the GECO database. It implies a change in the way the AMF interacts with professionals, which requires a number of the regulator's policies to be updated.

The tool will apply to all CIUs, with the exception of real estate investment companies, forestry investment companies, forestry investment groupings and securitisation vehicles, for which it will be possible to exchange information with the AMF via the ROSA extranet at a later date. In the meantime, an ad hoc process available on the ROSA extranet will be put in place for these CIUs.

In addition to the change of interface, in most cases investment management companies will fill in the information relating to CIUs directly in the new tool and will no longer have to send certain forms that were previously appended to the instructions applicable to CIUs. These appendices will therefore be removed from the guidance.

Investment management companies will also be able to check the progress of their application for a CIU directly on the ROSA extranet at any time, providing greater traceability than with the current GECO database.

Details on updating guidance documents

While the updated policy documents mainly concern the processes for exchanging information between the AMF and investment management companies, they do not entail any substantive changes in terms of the applicable rules, with one exception concerning changes of prime broker, which will no longer be subject to prior approval by the AMF.

The AMF guidance that has been significantly changed are the instructions relating to CIU authorisation and declaration processes.

Schedule

The relevant guidance documents are being published today, including versions that are clearly marked-up, to enable professionals to anticipate the consequences of transitioning to the ROSA extranet. They will come into force when the ROSA extranet, currently in the test phase, officially goes online in early 2024. The official launch date, and therefore the date on which these changes in policy will take effect, will be announced at a later date.

The relevant guidance documents are as follows (in French only)

• AMF Instruction DOC-2011-19 and compiled annexes: Authorisation procedures, preparation of a KIID and a prospectus and periodic reporting for French and foreign UCITS marketed in France
• AMF Instruction DOC-2011-19 and compiled annexes: Apparent changes
• AMF Instruction DOC-2011-20 and compiled annexes: Authorisation procedures, preparation of a KIID and a prospectus and periodic reporting for retail investment funds, funds of alternative funds and professional alternative investment funds
• AMF Instruction DOC-2011-20 and compiled annexes: Apparent changes
• AMF Instruction DOC-2011-21 and compiled annexes: Authorisation procedures, preparation of a KIID and a prospectus, and reporting for employee investment undertakings
• AMF Instruction DOC-2011-21 and compiled annexes: Apparent changes
• AMF Instruction DOC-2011-22 and compiled annexes: Authorisation procedures, preparation of a KIID and rules, and reporting for private equity funds
• AMF Instruction DOC-2011-22 and compiled annexes: Apparent changes
• Instruction DOC-2011-23 and compiled annexes: Authorisation and establishment processes for a KIID and a prospectus and periodic information for real estate collective investment undertakings and professional real estate collective investment undertakings
• AMF Instruction DOC-2011-23 and compiled annexes: Apparent changes
• AMF Instruction DOC-2012-06 and compiled annexes: Procedures for making disclosures and introducing changes, preparation of a prospectus and reporting for specialised professional funds and professional private equity funds
• AMF Instruction DOC-2012-06 and compiled annexes: Apparent changes

The relevant guidance documents more (in French only)

• AMF Instruction DOC-2008-03: Authorisation procedure for investment management companies, disclosure obligations and passporting
• AMF Instruction DOC-2008-03: Apparent changes
• AMF Position - Recommendation DOC-2011-25: A guide to the monitoring of collective investment undertakings
• AMF Position - Recommendation DOC-2011-25: Apparent changes
• AMF Position - Recommendation DOC-2012-10: Guide relating to employee investment undertakings
• AMF Position - Recommendation DOC-2012-10: Apparent changes
• AMF Position - Recommendation DOC-2012-11: Guide for retail and professional private equity funds
• AMF Position - Recommendation DOC-2012-11: Apparent changes
• AMF Instruction DOC-2013-21: Registration arrangements for legal entities, other than portfolio management companies, managing certain Other AIF
• AMF Instruction DOC-2013-21: Apparent changes
• AMF Instruction DOC-2014-03: Procedure for marketing units or shares of AIFs
• AMF Instruction DOC-2014-03: Apparent changes