MARCH 2022
10
Ristretto #Finance
“It’s important to show what we have built” Jean-François Terminaux, chairman of Finance & Technology Luxembourg, says the trade group is creating the world’s first international standards for support PSFs, which could be put in place this autumn.
Support PSFs are authorised by Luxembourg’s financial regulator, the CSSF, to handle certain operational tasks, such as managing IT systems. You told me earlier that your members, who are all support PSFs, have been discussing the certification process. What challenges have you been talking about? In Luxembourg, normally people know [what the support PSF authorisation is], but outside Luxembourg, it’s important to show what we have built over the last nearly 20 years now, and the knowledge we have, the processes we have, the professionalism that we have. One of the other really important topics… is how to bring the local regulation to something more international. Just to explain abroad, what is a support PSF? And so, we have worked with a huge team of people--who really know more about all these topics than me--and we decided last year that we will go to an ISAE 3000 standard. Why? Because it’s a kind of a basket, and you can put a lot of topics in. So you can build your own standard, I’m saying it like that, but it’s internationally recognised.... The idea of the standard is not to cancel the regulator’s circulars, it’s not. Because the circulars are the circulars. But the idea is to simplify the work of our members, simplify the work of the auditors and simplify the work of the CSSF. Let me explain. If [the work of obtaining the ISAE certification already] fulfils 70% or 80% of what the CSSF circulars require, then you just have to work on the 20% on top. Also, the CSSF just has to do a [bespoke review of the remaining 20%]. It’s less work for people.... You know, for some companies, it’s a lot, a lot, a lot of documents. Different documents for the same questions that you have to fill in, because it’s always the same questions. Different formats, but it’s always the same questions. The idea is to really simplify the work. If you simplify the work, everybody is happy. Then you could also show [that you are following international standards].
So the standards would not replace the licence from the CSSF? No, not at all... the [licence] and standards are different. The [licence] is something that you have received from the regulators, [while standards are] a reference. More and more regulation, more and more rules to follow. Luxembourg is a small country with a certain amount of people, so you have to find a way to be clever and ensure that you follow the rules, but if you can save time--and I hope somehow money--it will help everybody. So this is a voluntary standard that should make it simpler to comply with the regulators? To make it simpler for everybody: all players, regulators, auditors, our customers. We also want to extend, which is possible with an ISAE 3000. Why not insurance tomorrow? Insurers are using support PSFs, but they’re not regulated by the Commissariat aux Assurances, they’re regulated by the CSSF. So we are also in discussion with [the insurance industry association] Aca and with the CAA to ask, ‘what are your needs?’ When do you think that the standards could be published and take effect? Okay, my goal, Jean-François is speaking, end of June.... and, fingers crossed, we can present the results to the CSSF, the High Committee of the Financial Centre and ministry of finance during summertime, and then say, ‘okay, let’s go’ in September or October.
Jean-François Terminaux is managing director of IT services provider Damovo Luxembourg
Interview AARON GRUNWALD Photo GUY WOLFF
