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A few interesting findings from the European Securities and Markets Authority (ESMA) updated Sustainabable Finance Disclosure Regulation (#SFDR) Q&As: 🌍 Website disclosures: An AIFM must have a website and must clearly explain all revisions and changes to the information provided. This may include the website of the group to which the AIFM belongs. 📊 It is the ESMAs supervisory expectation that the templates for pre-contractual disclosure and periodic reporting are used for website disclosure – extra scrutiny of confidential information advisable. However, no obligation to disclose documents that would not otherwise have to be disclosed – such as the AIFMD or EuVECA mini-prospectus (Art. 23 AIFMD / Art. 13 EuVECA). 🌳 If a quota on taxonomy-aligned investments is given, pre-contractual disclosures must use turnover by default but can switch to CapEx or OpEx if more appropriate – may be interesting for VC funds! 🔭 ESMA confirms that a fund of funds must look through the underlying fund to the final investments to assess whether it holds “sustainable investments” and compliance must be ensured by the respective fund of funds – how should a fund of fund do this? 🔎 AIFMD sustainability risk DD must be made even if under SFDR an AIFM considers sustainability risks not relevant for its investment decisions. Summarized by YPOG's Fabian Euhus, Dana Franziska Ritter, and Florian Thrun.   ➡ Link to the complete document can be found in the comments below. #YPOG #Funds #VentureCapital #PrivateEquity

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