The Findel Group Strategy

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1 The Findel Group Strategy

2 2 The Findel Group is formed of Asset Managers focused on identifying common opportunities for operational efficiency in cross border distribution and where relevant recommending and promoting common solutions to the benefit of fund market participants and ultimately end investors.

3 3 Objective Our key aims are to:- Identify common opportunities to enhance operational efficiency in cross border distribution. Recommend and promote through a single voice, common solutions that would be of benefit to fund market participants and ultimately end investors. The Group cooperates with other existing working groups & industry bodies and participates in relevant forums across the industry to further its goals.

4 4 Identify common opportunities to enhance operational efficiency in cross border distribution The Findel Group members will work with industry groups to help develop and shape new and innovative solutions which broaden distribution opportunities, reduce cost and improve customer experience Explore and understand operational challenges to drive operational improvement within industry Use our shared experience to help create ideas and help influence the direction of operational change for cross- border markets

5 5 Recommend and promote common solutions Identify areas where operational efficiency can be either standardised or improved:- KYC/AML Distribution of products Transfers Settlement

6 6 The Group cooperates with other existing working groups & industry bodies and participates in relevant forums across the industry to further its goals Engage with regulators and industry groups (CSSF, IF & IA) Big 4 Audit Firms E&Y, KPMG, PWC, Deloitte s Industry Bodies Investment Association ( IA), Financial Services Ireland (FSI), ALFI & HKIFA, Regulators FCA, CBI, CSSF, HKMA Third Party Providers Calastone, Euroclear, Clearstream, Fund Square, TA / FA/ Custodian - BNYM, JPM, SSB, CITI, BNP Implement two-way information flow between industry groups in respect of the following topics:- AML Blockchain / FinTech Disruptors Distribution Regulatory Changes Market developments

7 7 Working Groups The Findel Group works to facilitate change and improvement within the industry through open discussion and sharing of information, knowledge and ideas amongst its members. We currently have the following three working groups:- Transfers AML/KYC Due Diligence

8 8 AML/KYC Working Group The key objectives of the AML/KYC Working Group are:- Promote standardised process within AM industry Review new propositions:- FundSquare solution Portal & Swift KYC Registry. BlockChain Industry solutions Assess impact of regulatory changes

9 9 Due Diligence Working Group The key objectives of the Due Diligence Working Group are:- Produce white paper on distribution risk in the Know Your Distributor process of cross-border global distribution To promote the white paper internally and with industry peers and groups Evaluate impact of regulatory changes Including MiFID II and the ESA Joint Guidelines under Article 17 and 18(4) of 2015/849 irt: Impact on the requirements for Distribution Due Diligence

10 10 Transfers Working Group The key objectives of the Transfers Working Group are:- Promote standardised processes between transfer agent and distributors/clients Produce White Paper on the issues impacting Transfers Address issues with Clearstream and Euroclear Look at automation opportunities to reduce costs and risks and increase client satisfaction

11 11 Promotion of Findel Group Communications strategy Regular Updates to Website Linkedin Group Ensure we have approached all significant AM s who operate crossborder and actively seek additional Asset Manager members Quarterly Meetings Sub Working Groups

12 12 Topics of interest (feedback from members) AML / KYC FundSquare solution Portal & Swift KYC Registry (included) Funds DLT Distributed Ledger Technology options in Lux, Dublin, UK Artificial Intelligence use of Natural Language Product MIFID Distributor Oversight tools Liquidity Tools required when there are potential illiquid markets/market incident that would need a) deferral >10% b) full deferral c) suspension etc. Regulatory Changes i.e. GDPR Fund Settlement Cycles (following US move to T2)

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