Camilla Lindberg is a senior professional with extensive experience within Luxembourg based Management Companies, focusing on Investment Fund governance, in particular the oversight of delegated functions.
Lindberg Consulting was created during the summer 2024 to enable independence in selecting mandates, business partners and clients.
Camilla is a well-versed professional specialised in governance of Luxembourg based investment funds. Her offerings are the following:
Camilla is an expert in the niche of delegate oversight. This means that she can support her clients’ teams with that specific knowledge and experience.
Camilla believes that as a local Luxembourg based director with long operational experience of working with fund boards, and all other Board reporting counterparties, she is able to bring local governance expertise to the Boards and provide clarity regarding cross-border differences related to the implementation and interpretation of regulatory expectations and best market practices.
Independent directors play a critical role in ensuring impartial assessment and supervision, as they are not entangled in the same personal or corporate interests as other directors who hold significant shareholder positions, or are involved in the management of the company.
No financial or material connection to the organisation or its affiliated individuals, enables independent directors to contribute with objectivity and impartiality to the discussions and choices made by the board, to safeguard the interests of minority shareholders, influence and ensure corporate credibility, governance standards, and risk management.
CSSF Circular 18/698 refers to KPI monitoring, as part of the expected toolbox when performing ongoing monitoring of delegated activities. KPI monitoring is being understood, implemented and managed differently within the industry, depending on the nature, risk and criticality of the delegated activity and depending on the monitored products.
The industry seems to believe that the ongoing monitoring can be sufficiently solved with the implementation of a quarterly KPI questionnaire. We believe this may be contra productive and even harmful, if the questionnaire is implemented for the wrong purpose.
The problem is that the methodology is very similar to the DDQ, making the use questionable, and likely be rejected by global marketing intermediaries. The Luxembourg fund industry may be exposed to several risks, if we implement mechanical activities that do not make sense from a data collection perspective.
We believe that we can perform qualitative ongoing monitoring on Marketing Intermediaries without another questionnaire. We would propose active monitoring as the preferred strategy, when meeting our ongoing monitoring requirements. This might not be the case for other delegated activities.
The governance structure should be proportionate and reflect the nature, scale and complexity of the delegated activity. We can see that monitoring activities are becoming mechanical and as a consequence, we might not “see the forest through all the trees”.
The fact that we consider implementing mechanical activities rather than performing active and meaningful monitoring is becoming a critical issue. Reporting is then required to tick a box, rather than serving a real purpose.
Knowing the particularities of international marketing intermediaries, we believe that Luxembourg, as the second largest fund industry worldwide, need to be very careful with what we commit to in order to continue to meet regulatory expectations and avoid exposing ourselves to unnecessary risks.
Operational experience of the implementation of robust oversight procedures of Investment Management and Distribution activities since 2015. Circular 18/698 was published in 2018 and the Circular provided additional clarity and guidance on governance expectations. The Circular include general guidance on all delegated activities and the industry must assess all risks related to the particular activity, and implement relevant and meaningful oversight activities.
It is vital to understand the delegated activities to identify relevant oversight activities for the purpose of minimising risk exposure.
Choosing the right service provider is critical for the success and efficiency of your business. You need to evaluate their expertise and experience, understand their services and the cost, quality assurance, and last but not least, certify scalability and flexibility.
Camilla has hands-on experience in performing oversight on delegated functions since 2015. This is a small selection of her robust portfolio. Please download her CV for a more detailed overview.
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