Region

Jurisdiction

Regulator

2026-06-18

Order to ACM Forvaltning A/S Regarding Deficient Governance Documents and Misleading Marketing

The Danish Financial Supervisory Authority has ordered ACM Forvaltning A/S to implement adequate governance processes and documentation for its PRIIP KIDs and to eliminate misleading marketing practices. The regulator found that the company failed to include required stress scenarios in its key information documents and used non-statutory methods to calculate and present expected returns, thereby overstating favorable outcomes. The order mandates immediate compliance with EU regulations regarding document accuracy, balanced risk presentation, and the exclusive use of legally prescribed calculation methods.

Denmark

Finanstilsynet Denmark

Decision 18-06-2026

On June 16, 2026, the Danish Financial Supervisory Authority ordered ACM Forvaltning A/S to establish adequate processes and governance documents for the handling of central investor documentation and to remove misleading marketing.

ACM Forvaltning A/S has produced and published central investor documents (PRIIP KIDs) for its alternative investment funds without ensuring that the documents comply with applicable rules regarding content and format. The PRIIP KIDs do not contain the required result scenarios; specifically, the stress scenario is missing, and favorable results are highlighted at the expense of unfavorable ones. Furthermore, the company has marketed expected returns calculated using a method other than the statutory method [1], which is not in accordance with the regulations.

PRIIP KIDs must be accurate, fair, clear, and not misleading. They must contain at least four result scenarios, including a stress scenario, and present the results in a balanced manner in accordance with the fund's risk and return profile. Expected returns must be calculated and presented using the statutory method. Fund managers must have processes and governance documents that ensure that the documentation and marketing comply with these requirements.

The Danish Financial Supervisory Authority has therefore ordered ACM Forvaltning A/S to have processes and governance documents for PRIIP KIDs that ensure that the company's central investor documentation is at all times accurate, fair, clear, and not misleading. [2]

The Danish Financial Supervisory Authority has also ordered ACM Forvaltning A/S to use the statutory method for calculating and presenting expected returns for its funds and to remove misleading marketing that uses other calculation methods to the detriment of the statutory method. [3]

[1] Cf. Annex IV, paragraph 44, of Regulation (EU) 2017/653.

[2] Cf. Article 57(1)(a) of Regulation (EU) 231/2013, in conjunction with Article 6(1) of Regulation (EU) 1286/2014.

[3] Cf. Article 9 of Regulation (EU) 1286/2014, in conjunction with Annex IV, paragraph 44, of Regulation (EU) 2017/653.

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