Regulatory AlertsGuide on the Organization of Risk Management, Compliance, and Internal Control within Portfolio Management Companies
The Autorité des marchés financiers (AMF) issued Position-Recommendation DOC-2014-06 to define expectations for the organization and functioning of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). The guide details how these control functions interact and applies to SGP entities managing UCITS or AIFs, or providing portfolio management services for third parties. Although the document has not yet been updated to reflect MiFID II transposition, it remains the primary reference for these organizational requirements.
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III - Service Providers III. 1 - Investment Service Providers III. 1.2. Organizational Rules Doctrine Organizational Rules
Guide on the Organization of the Risk Management Framework within Portfolio Management Companies
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Applicable as of March 21, 2022 Position - Recommendation DOC-2014-06
Download Viewed Version Summary Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés financiers regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties.
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Articles 312-43 to 312-48, 318-4, 318-5, 318-38 to 318-56, 321-23 to 321-27, 321-30 to 321-36, 321-62 to 321-65, 318-29 to 32, 321-76 to 321-81, 321-79, and 321-83 to 321-92 of the General Regulation
Articles 38 to 49 and 60 to 62 of Commission Delegated Regulation (EU) No 231/2013 of December 19, 2012
Articles 22 and 25 of Commission Delegated Regulation (EU) 2017/565 of April 25, 2016 Archives
Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés financiers regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties.
Download the doctrine Reference texts
Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés financiers regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties. This document has not been updated regarding texts transposing MiFID II and separating the legal regime of investment firms and portfolio management companies. This update will be carried out shortly.
Download the doctrine Reference texts
Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés financiers regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties.
Download the doctrine Reference texts
Articles 38 to 49 of Commission Delegated Regulation (EU) No 231/2013 of December 19, 2012
Articles 313-1 to 313-7; 313-53-2 to 313-58; 313-60; 313-62 to 313-71; 318-4 to 318-6; 318-38 to 318-56 of the AMF General Regulation
Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties.
Download the doctrine Reference texts
Position-Recommendation DOC-2014-06 aims to clarify the expectations of the Autorité des marchés regarding the functioning and organization of compliance, risk management, internal control, and periodic control functions within portfolio management companies (SGPs). This guide specifically clarifies how the different control functions are structured and interact. It addresses SGPs that manage UCITS or AIFs and/or provide the investment service of portfolio management for third parties.
Download the doctrine Reference texts Legal notices: Publisher: The Director of the Communication Department of the AMF. Contact: Communication Department, Autorité des marchés financiers - 17, place de la Bourse - 75082 Paris Cedex 02