WThe purpose of this article is to point out that there’s help at hand.
SFDR is here! What now?
10 March 2021 – updated 15 March 2021
Yes indeed it came into play 10th March
…And if you need to get to grips with the requirements as well as the opportunities and threats, or to answer the What Now question, you are in the right place. In our earlier article – Are You Sure SFDR Is NOT For You, you can dive deeper into the considerations around the subject. We also delivered a series of videos on individual SFDR topics (see these on our LinkedIn Page).
This article focuses on the what now?
There are two ways firms can go:
1. You are an EU investment firm impacted by SFDR
If this is the case, you will know that the first date in a series of implementation steps for greater transparency and disclosure came into effect on 10 March 2021.
If you are in-scope, you will be aware that SFDR – the Disclosure Regulation – requires you to provide information on the principal adverse impacts (PAIs) of sustainable factors (or decide not to do so with a rationale).
You will have up-dated your product / portfolio information in relation to “sustainable factors” and “sustainability risks” for “sustainable investments” and will be setting out the PAIs.
These changes will have affected your risk and remuneration policies, your pre-contractual disclosures, and imposed additional disclosure requirements on your portfolios that promote environmental or social characteristics and your methodologies for assessing these.
You will have also amended your website to cover all these matters where they apply to your firm.
2. You are not an EU investment firm (or managing EU based portfolios) and you may have decided that SFDR does not apply to you.
Importantly, as we at Merlys have identified in our earlier publication and videos on ourLinkedIn page, SFDR may turn out to be applicable.
This could be either for commercial reasons (your products will no longer be easy to compare to those of your competitors) or your clients may require you to comply.
There are a variety of tasks and decision-making processes with which firms in either of the above categories might need assistance. The purpose of this article is to point out that there is help at hand.
Merlys can help with the small and the largest tasks… We help you
- to understand the implications of SFDR for your firm
- to consider the strategic impacts of SFDR on your business to determine, if it is not mandatory for your firm, whether you should voluntarily comply
- by undertaking a gap-analysis between your existing documents and the SFDR requirements to identify whether any up-grades are required to existing disclosure documents to ensure compliance (whether voluntarily or mandated)
- by providing you with the tools to undertake any analysis for yourselves
- by assisting with up-dating your product development processes to include SFDR considerations
- enhance your policies and procedures – working with your legal, compliance, product and operational teams as required.
We’re ready to help right now. We’re happy to discuss your needs, more about the help at hand or any aspect of this or our other SFDR publications/videos (links at the top of this article).
Call or contact us now via any of the contact methods shown:
Verena Charvet MBA,
Solicitor and Senior Partner at Merlys
Contact/Call us at Merlys | +44(0) 20 8154 6031
Follow us: Merlys: https://www.linkedin.com/company/merlys/
This briefing note is intended to act as general guidance and is not intended to offer specific legal advice. Merlys is very happy to assist you with any aspect of the content in this article, as it relates to your business.