The investment management company must not disclose to certain investors or certain intermediaries information on the breakdown in fund assets that might facilitate market timing or late trading transactions. In particular, the investment management company must not disclose the portfolio’s composition in real time.
However, the AMF position paper on market timing and late trading transactions (DOC-2004-07, as amended in November 2015) does provide for some exceptions.
With this in mind, the investment management company has adjusted its in-house procedure to comply with these new regulatory provisions. For example, it may reply to requests from certain professional investors who are supervised by the ACPR, AMF or equivalent European authorities, who must themselves comply with the regulatory requirements of Directive 2009/138/EC (Solvency 2).