The permission was never the finish line
When the 2022 Securitisation Law reform opened up active management of debt assets in Luxembourg, a lot of platforms treated it as the finish line. New permissions, new pitch, new wave of mandates. Fair enough at the time.
But that was four years ago now and the CSSF FAQ everyone built their offering around is the same one every competing platform read too. Having the permission isn’t the differentiator anymore.
What wins mandates now
What actually wins an EAM or private bank mandate now is much less interesting to put on a slide: how fast you can get a structure live, how cleanly the compartment is documented and ring-fenced, whether the CSSF authorisation question gets answered properly upfront instead of becoming a surprise three weeks into a deal. Luxembourg already gives you the better starting point here, the legal certainty around compartmentalisation and the regulatory framework itself is more robust than most of what’s on offer elsewhere. But that’s a platform advantage, not an excuse. It still has to be executed well deal by deal.
None of that shows up in a pitch deck. It shows up in how the second deal with a client goes, and whether they come back for a third.
You’re not being compared to where you started
The uncomfortable bit is that nobody on the other side is comparing you to where you were when you first started. They’re comparing you to whoever else is in the room this quarter, Luxembourg against another jurisdiction, one issuer against another, your onboarding timeline against someone else’s promise of a faster one and costings of course! Being better than you used to be doesn’t matter if it’s not better than the alternative.
The unglamorous, ongoing work
So the actual work, on an ongoing basis, looks fairly unglamorous:
- Going back through structures that “work fine” and asking what a sharp counterparty would actually object to, rather than waiting for them to raise it
- Treating each bit of new regulatory guidance as a chance to get ahead rather than just something to comply with
- Building out the onboarding and due diligence process before deal volume forces it, not after
- Reviewing service providers to ensure they are relevant, cost-effective and match up with your own values and approach to quality of service.
The real risk
In the end, the risk isn’t losing a pitch, that forces you to react and fix something. The real risk is winning mandates without knowing exactly why and not noticing when the reason quietly stops being true.
Contact Gilderstone to discuss how we can support your Luxembourg SPV.