Fund Distribution Alert 2020-18

Fund Distribution Alert 2020-18



Said Fihri

Partner, ADV – Investment Services

KPMG in Luxembourg



Updated CCR application form for foreign funds

The Comisión Clasificadora de Riesgo (CCR) has released an updated version of its application form dated October 2020, which must be completed to market a fund under the pension fund regime in Chile.

Below is a non-exhaustive list of the changes made:

  1. From now on, the following documents must be signed electronically: the application form, the Administradora de Fondos de Pensiones (AFP) letter, the preliminary information, the statement, and the updating commitment.
  2. The assets under management of the holding company, the management company, the investment manager and the sub-investment manager should now be indicated in USD. For the investment manager and the sub-investment manager, there are no longer any exclusions.
  3. In Appendix N° 4: Depository/Custodian, the “applicable legislation” section has been removed, and assets under custody should be specified in USD.
  4. In Appendix N° 5: Investment Objectives and Policies, in the “investment policies” section, asset classes should be considered when mentioning “investment restrictions and criteria or diversification strategies”.
  5. In Appendix N° 6: Use of Financial Derivatives Policy, the wording of the “leverage” section has been modified.
  6. In Appendix N° 7: Borrowing Policy, the “borrowing” and “legal limits” sections have been modified.
  7. In Appendix N° 10: Liquidity of the Shares, it has been specified that this concerns open-ended mutual funds. In the “suspension and restriction” section, mechanisms that protect shareholders from the impact of dilution or transaction costs caused by shareholder activity should be mentioned.
  8. Appendixes N° 11-A and 11-B: Liquidity of the Instruments have been reworked.     
  9. In Appendix N° 13: Property Participation of the Fund, it has been specified that this concerns open-ended mutual funds.
  10. In Appendix N° 14: Asset Allocation, the requirement to indicate a benchmark has been removed.
  11. In Appendix N° 15: Conflicts of Interest, previous indications of what should be mentioned here have been removed or reduced.

The new application form is available here.

Please feel free to contact us if you require any additional information.


Said Fihri
+352 22 51 51 7892

Stephanie Zedda
+352 22 51 51 7271

Please note that any information provided is general in nature, is based on the latest publicly available information as analyzed on a best endeavor basis and does not constitute any specific legal opinion or advice.

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