Centaur Financial Limited (“CFL”) provides independent depositary services for managers of non-EU domiciled alternative investment funds, assisting clients in meeting their Alternative Investment Fund Manager Directive (“AIFMD”) responsibilities. Our experts assist clients with the AIFMD regime and work to ensure they meet their depositary requirements in a timely and efficient manner.
DEPOSITARY SERVICES SUMMARY
CASH FLOW MONITORING: (ARTICLE 21.7)
The depositary is responsible for properly monitoring the AIFs cash flows. At CFL, we:
- Ensure access to all cash account information held by or on behalf of AIFs, including payment information relating to subscriptions by investors
- Ensure all institutions where accounts are held meet the requirements of Directive 2006/73/EC (regulatory status and verification)
- Conduct cash flow movement reconciliations
- Monitor unusual or significant cash flows and escalate to the AIFM
- Review the adequacy of cash monitoring controls annually
- Ensure the resolution of discrepancies identified by reconciliation controls
- Check the consistency between CFL’s cash position records against those of the AIFM.
VERIFCIATION OF NON CUSTODY ASSETS: (ARTICLE 21.8 B)
CFL provision services under Article 21.8(b) to carry out the below duties:
- Ensure access to all the relevant information required to perform the ownership verification and record-keeping duties
- Maintain a record of ‘other assets’ (non-custody holdings)
- Verify ownership of these assets at the valuation point with independent sources.
OVERSIGHT FUNCTION: (ARTICLE 21.9)
CFL Oversight Services include:
- Conduct monitoring to provide reasonable assurance that the value of the AIF’s units or shares has been calculated in accordance with applicable laws, the AIF’s constitutional documents and the provisions of Article 19 of AIFMD.
- Monitor the AIF’s and the AIFM’s compliance with any investment restrictions and leverage limits procedures.
- Perform checks to provide reasonable assurance that trades are settled within an acceptable timeframe.
- Ensure AIF income is applied in accordance with AIF rules and the AIF’s constitutional documentation.
- Implement controls to provide reasonable assurance that investor transactions have been processed correctly and in accordance with applicable laws and the AIF’s constitutional documentation.
- Establish a comprehensive escalation procedure for reporting irregularities.