Investment Funds Distributor Due Diligence Questionnaire

Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, an industry working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels. The questionnaire saves funds and distributors time, difficulty, and expense by streamlining the process of distributor oversight.

Effective 1 June, 2020, the DDQ is publicly available for use by any fund manager or distributor. The working group will review the document for updates on an annual basis to reflect any changes in the market or regulatory framework.

For additional information, or if you have questions about the due diligence questionnaire, please contact Ahmed Elghazaly, director of investment operations, at ahmed@ici.org.

About the Working Group

To develop industry standards for distributor oversight and due diligence practices for UCITS and AIFs, ICI Global brought a working group together to develop a single due diligence questionnaire for cross border UCITS and AIFS. Structured to ensure equal representation of distributor and fund manager perspectives, the working group included representatives from distributors (including Morgan Stanley, UBS, Allfunds, and Julius Baer), and more than 30 fund managers and representatives from several trade bodies (including the European Fund and Asset Management Association (EFAMA), the Association of the Luxembourg Fund Industry (ALFI), the Irish Funds Association, the Investment Association (IA), the French Asset Management Association (AFG), and the Italian investment management association). To have balanced representation from the buy and sell side, the working group is co-chaired by Marta Oñoro Carrascal, global head of legal of Allfunds, and Alain Mandy, global vice president and chief operating officer of Wellington Management.

The goal of the working group was to create a comprehensive questionnaire which fund distributors and platforms could complete once annually and make available to all fund companies requesting the information. The project began with the collection of existing practices and widely used questionnaires, then went through multiple iterations to include all regulatory and cross border distribution considerations. The result is an industry standard questionnaire that can be used by UCITS and AIFs distributed anywhere including Europe, the United States, Latin America, or elsewhere.