Q. I am a UCITS management company operating or planning to operate in the manner of a third party management company [As set out in the ESMA Brexit opinion (ESMA34-45-344), reference to third party fund management companies / white-label fund management companies, generally refers to “fund managers that provide a platform to business partners by setting up funds at the initiative of the latter and typically delegating investment management functions to those initiators/business partners or appointing them as investment advisers.”]. What should I consider and what actions should I take when taking on new business?
A. Fund management companies need to have sufficient resources to enable them to carry out their functions to the required standard, taking into account the nature, scale and complexity of their business. This is of particular relevance to third party management companies where the on-boarding of new business may change the nature of, or increase the number of delegate
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