As fund Custodians and Depositories, the Bank is expected to conduct and fulfil a strict oversight function over the fund’s portfolio and the Manager’s actions. For this purpose, the Bank has set a number of regular compliance tasks to assist it in so doing amongst which are:-
- Reconciliations of holdings – Strict procedures are in place so that the Bank’s positions are reconciled with those booked by the fund’s administrator as well as with the Bank’s subcustodians and depositories – this procedure helps eliminate any possible loss of assets or discrepancies in the amount of units or shares held by the fund.
- Reconciliations of pricing – Procedures are also in place to identify any significant discrepancies that may be considered to be inconsistent with the Offering Supplement and Offering Memorandum. On-going monitoring is designed to highlight and identify discrepancies of any nature be it Foreign Exchange, short deliveries and settlements, pricing, accrued interest, etc.
- Reconciliations of exposures – Reconciliations are also conducted with a view to monitor the exposure limits of the portfolio as set out in the Offering Documents.
- Reconciliations of shareholder register – In order to comply with AIFMD, Sparkasse Bank Malta plc is expected to reconcile the subscriptions orders with the subscription proceeds, as well as the number of units or shares issued as a result of the subscription proceeds received. The same applies to redemption orders.
- NAV verifications – the Bank carries out a verification of NAV calculation periodically.
- Look through functions and other regulatory and compliance issues – the Bank promotes and embraces good governance and prudential management – and applies this in all it does for and on behalf of the fund – the Bank will therefore apply further controls and implement checks and balances to make sure that this spirit is being reflected in full throughout the fund’s internal operations.