Interview : Bolder Luxembourg

What are the fund services offered by Bolder Luxembourg, and how do they differ across regulated and unregulated Luxembourg vehicles (e.g., RAIF, SCSp, SIF)?

At Bolder Luxembourg, we support clients throughout the entire lifecycle of a fund. Depending on the structure, this can range from fund accounting, investor reporting, transfer agency and regulatory reporting, all the way to entity management, SPV administration, corporate secretarial services and governance support.

What is interesting in Luxembourg is that people often talk about "a fund" as if every vehicle looks the same. In reality, a SIF, a RAIF and an SCSp can feel quite different from an operational perspective.

For a regulated vehicle such as a SIF, there is naturally a greater focus on regulatory oversight, governance processes and stakeholder coordination. You are working closely with the AIFM, the depositary, auditors and legal advisers, and there are more formal reporting and control requirements.

For a RAIF, many managers appreciate the speed and flexibility of the product, but in practice it is by no means a "light-touch" structure. Because supervision largely comes through the appointed AIFM, operational expectations remain very high. In many cases, investors expect the same institutional standards as they would from a fully regulated product.

For an SCSp, particularly in the private equity and real estate space, the focus is often on flexibility and tailoring the administration model to the investment strategy. But while the legal form may be simpler, investor expectations certainly are not. Institutional investors today expect professional reporting, transparency and governance regardless of whether the vehicle has a regulator's label attached to it.

Ultimately, our role is to adapt the operating model to the client's structure and strategy. A venture capital fund investing in start-ups has different needs from a pan-European real estate platform or a private credit fund. There is no one-size-fits-all solution, and frankly, if there was, Luxembourg would be a much less interesting place to work.

As an experienced Luxembourg market player, what are your expectations of the regulatory environment for the next 5 to 10 years, particularly regarding AIFMD II implementation?

If we had to summarise the next decade in one sentence, we would say: more transparency, more data, and more accountability.

AIFMD II is another important step in the continued maturation of the European alternative investment market. While some market participants initially focus on the additional obligations, we believe the broader objective is to create a more harmonised and resilient framework for alternative investments across Europe. To be honest, we don't think the biggest challenge will be understanding the rules. The biggest challenge will be operationalising them efficiently. Most managers know what they need to do: the question is how to implement these requirements without creating unnecessary complexity and cost.

Beyond AIFMD II, we think we will see three major developments.

The first is increased regulatory focus on governance and oversight. Regulators want to understand who is making decisions, where those decisions are being made and whether firms have sufficient substance. This trend is already visible today and we expect it to continue.

The second is the growing importance of data. Historically, many reporting requirements focused on delivering information. Increasingly, regulators and investors are focusing on the quality, consistency and traceability of that information. In other words, sending a report will no longer be enough. You will need to demonstrate that the underlying data is reliable.

The third is the convergence of regulation and technology. Regulatory reporting, AML controls, ESG disclosures and risk monitoring are becoming increasingly data-driven. The firms that succeed will not necessarily be those with the biggest compliance departments, but those that can combine expertise with technology.

As for Luxembourg, we remain very optimistic. Every few years, someone predicts that Luxembourg's best days are behind it. Yet the industry continues to grow, adapt and attract international managers. Luxembourg has built a strong ecosystem of lawyers, administrators, AIFMs, depositaries and regulators. That ecosystem is difficult to replicate.

So while regulation will undoubtedly become more complex, we believe Luxembourg is exceptionally well positioned to turn regulatory change into a competitive advantage rather than a disadvantage.

Bolder operates across multiple jurisdictions (Luxembourg, Netherlands, British Virgin Islands, Cayman Islands). How does this global footprint translate into added value for clients structuring cross-border Luxembourg funds?

One thing we have learned over the years is that very few fund structures stop at the Luxembourg border.

A manager may be based in London, the fund in Luxembourg, holding companies in the Netherlands, financing vehicles in another jurisdiction and investors spread across the globe. The challenge is often not creating the structure. The challenge is operating it efficiently.

This is where an international organisation can make a real difference.

Because Bolder has teams across multiple jurisdictions, we understand both the local requirements and the broader picture. Instead of clients having to coordinate several unrelated service providers, they have one partner helping to connect the different pieces of the puzzle.

This creates efficiency, but more importantly, it reduces friction. The less time a fund manager spends chasing administrators, corporate service providers and various advisers across different time zones, the more time they can spend focusing on investments and investor relations.

What clients increasingly appreciate is consistency. They want the same quality standards, the same responsiveness and the same understanding of their structure regardless of where a particular entity sits.

In a way, our role is similar to that of a conductor of an orchestra. The individual instruments are important, but somebody still needs to make sure everyone is playing the same piece of music at the same time.

Fortunately, unlike in a real orchestra, nobody in fund administration asks for a solo.