What requirements are there for minimum fund management activity by the fund- and investment manager?
A fund manager shall, when applying for the new Fund Agreement, show that it has managed one or more funds for a continuous period of three years before entering into the agreement. The fund manager must have been authorized to conduct fund operations by the relevant regulatory authority throughout this period.
Acceptance of new “Code of Conduct”, assessing suitability for the Premium Pension Fund Platform, what does that mean?
The Pensions Agency will review the suitability of the fund manager, its representatives and its affiliates, such as, but not limited to: personal conduct and reputation, ability to put pensioners' interests first, and not cause damage to the confidence for the Premium Pension System.
Good practice within the Premium Pension Fund Platform is, for example, that the fund does not use:
· inappropriate business practices or hidden fees
· misleading marketing or sales through other products
· inappropriate investments (considering complexity etc.)
Good practices also includes responsibility for closely related business partners.
What fees do the Pensions Authority impose?
The pension authority shall, by law, charge each fund a fee for:
· application processing – SEK 75 000 for the first application for a fund agreement of a fund manager, and SEK 10 000 for subsequent fund agreement applications of a fund manager
· ongoing review and follow-up – SEK 32 000 per year for each fund agreement
Payment of application fee from Sweden must be made to Bankgiro 5298-3772 or directly to account number 12810123152 in Danske Bank. Foreign payments are made to IBAN number SE1812000000012810123152, BIC / SWIFT address: DABASESX.
What minimum requirements are there have regarding sustainability work in the fund management?
A fund manager must have signed the UN-supported Principles for Responsible Investments (PRI), or be subject to the signing of PRI principles made by the fund manager's Group. The requirements for sustainability apply both during the contract signing period and during the contract period.
· If the fund manager delegates the management to an external asset manager, the fund manager shall ensure that the external asset manager has signed the PRI principles.
· If the fund invests in other funds, the fund managers of these funds must also have signed the PRI principles.
· When merging into another fund, the receiving fund must also have signed the PRI.
However, this should not be interpreted as a prior notice. Further guidelines are under development.
What requirements are there regarding relevant and representative track record for each fund?
Swedish law stated that each fund shall have at least three years of coherent return history by the time of the application and throughout the term of the agreement.
In order to fulfil good practice in the premium pension area, the Pension Agency’s current assessment is that the return history should also be relevant and representative of the investment strategy the fund intends to have during the agreement period. This means that the Pensions Agency will likely not allow any significant changes to the Fund's investment philosophy, investment orientation or general strategy at the time of application or during the term of the agreement.
However, this should not be interpreted as an advance ruling. Further guidelines are under development.
Who can apply for a fund agreement?
The Swedish Pension Agency will enter into fund agreement with fund managers. A fund manager, according to Chapter 64, § 3 second paragraph 1 of the Social Insurance Code, is a collective investment undertaking, UCITS fund provider or management company entitled to conduct fund operations in accordance with Chapter 1, § 1, of the Swedish UCITS Act (2004:46). Fund managers can be Swedish as well as foreign fund managers. The fund manager may delegate investment management (to an “external investment manager”) or fund distribution as long as the fund manager comply with the fund agreement’s definition of “fund manager”.
Regarding the application, may fund managers submit their document regarding conflicts of interest in English?
Yes, given that all questions in the application form regarding conflict of interest are answered in Swedish.
Does all applications for the fund manager’s funds have be submitted at the same time?
No, you apply for one fund agreement per fund and hence, may choose to submit the individual applications at different times. However, if the fund manager wishes to submit applications for more than one fund at the same time, please follow the instructions given in the application form.
What requirements are there for minimum fund management activity by the fund- and investment manager?
A fund manager shall, when applying for the new Fund Agreement, show that it has managed one or more funds for a continuous period of three years before entering into the agreement. The fund manager must have been authorized to conduct fund operations by the relevant regulatory authority throughout this period.
External investment management may only be conducted by an external investment manager with authorisation to administer securities funds or conduct discretionary portfolio management with regard to financial instruments and who has managed capital for at least three years.
Who does the "Document stating which representatives that may represent the Fund Manager in trading" refer to, especially when the fund manager has outsourced fund trading?
It refers to the representatives that may represent the fund manager in trading, does not have to be within the fund manager's organisation. Will to some extent be the same representatives that apply for Secure-ID token.
Do the appendices constitute contractual content and thus, should be submitted with the application to enter into a fund agreement?
Yes, appendices A, B and C constitute contractual content according to 2.1 and should be submitted, initialled on each page, when applying for a new fund agreement.
