structured pricing process, its formalization, degree of sophistication and level of independence from the portfolio manager
Unterforen: Define and Implement a Structured and Formalised Pricing Process, Independent Analysis of the Fee Structures, Periodically Review of the Level of Cost, Sustainability of the Costs

Undue costs means costs in accordance with the 10 elements as detailed in paragraph 19 of the ESMA supervisory briefing.
The CSSF reminds IFMS that the pricing process to be defined and implemented must take these criteria into account in order to assess whether costs are appropriate.
Unterforen: Costs should be consistent with the Investment Objective of the Fund and do not prevent to achieve this Objective, Costs should be linked to a Service provided in the Investor’s Best Interest, Costs should be proportionate compared to Market Standards and to the Type of Service provided, Costs should be consistent with the Characteristics of the Fund, Costs should be sustainable considering the Expected Net Return, the Risk Profile and Investment Strategy, Costs should ensure Investors’ Equal Treatment, Costs should not be of material Prejudice to the Interests of any Class of (potential) Unitholders, Costs should not be duplicated, Costs should be properly separated and accounted for, Costs should be clearly disclosed to Investors

related party transactions and the related implementation and monitoring of an adequate conflicts of interest policy

the accuracy of the calculation of Ongoing Charges as well as the implementation of a documented internal approach for the definition of what charges shall form part of the amount to be disclosed

costs charged to low AuM Funds and an ongoing analysis led by the CSSF of potential outlier, i.e. funds charging fees much higher than their peers