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Guidance · AMF

Guide on the Organization of Risk Management, Compliance, and Internal Control within Portfolio Management Companies

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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

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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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Reference texts

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

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