On March 23rd 2015, the CSSF published Circular 15/608 (the "Circular"), which amends the date of entry into force of CSSF Circular 14/587 ("Circular 14/587") on the provisions applicable to credit institutions acting as custodian banks of Luxembourg undertakings for collective investment in transferable securities ("UCITS").
As further described in a previous article dated July 2014, the aim of Circular 14/587 is to align the requirements applicable to UCITS custodian banks with the future requirements of Directive 2014/91/EU of July 23rd 2014 on UCITS as regards depositary functions, remuneration policies and sanctions ("UCITS V Directive").
The initial deadline applicable to UCITS custodian banks in order to comply with Circular 14/587 was December 31st 2015.
Considering the fact that the implementation of the UCITS V Directive in Luxembourg must occur by March 18th 2016 and considering that the various delegated acts concerning the UCITS V Directive will only be published during the second and third trimester of 2015, the CSSF has adopted the Circular in order to align the deadlines, so that the entry into force of Circular 14/587 has been postponed to March 18th 2016.
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