- Before
- “I don't need more alerts. I need to know which of our 486 funds a French circular actually touches, and who owns the fix.”
- Now
- Opens an impact map already tested against all 486 funds, decides the one call the agents dispute, and proposes it to Legal with her reason.
One French-only circular, from capture to owned and attested actions
Quillfield Capital runs 486 funds and sub-funds in 11 legal entities and 9 domiciles. On Friday, October 16, 2026, Luxembourg's CSSF publishes Circular 26/918 on liquidity stress testing and AIFMD II liquidity management tools, in French only. Here is what happens next, screen by screen, in the working solution.
- 01Tuesday, 9:02 a.m.
Six things need her, in order
Priya Raman · Regulatory change managerOvernight the agents read 11 publications and opened 2 changes. Priya's home shows 318 publications in the last 30 days, 23 awaiting triage against a 5-business-day SLA, 186 open changes and 1,124 open actions, 3 of them overdue and escalated to Marcus Bell. First in line is the CSSF circular, where the Checker agent disagrees on one fund.
Checker agent: “I agree on 485 of 486 calls. I disagree on Private Credit Evergreen … I put it at 71%; please decide.”
- 02The publications queue
Every publication, in its own language
Watcher agentThe Watcher agent reads every source daily in the original language and sets the English title beside it: a BaFin interpretive decision on sustainability-related fund names, an AMF FAQ on SFDR, an SFC FAQ on dual-counter ETFs. Each carries a relevance score. 254 were ruled not relevant, each with a reason, and 20 a week are sample-checked by an analyst.
“BaFin website timed out at 6:00 a.m. Two German-language publications may be waiting. The Watcher agent retries at 10:00 a.m.”
- 03Friday, 6:12 p.m.
A French-only circular, English beside every paragraph
Watcher and Reader agentsThe CSSF published the circular at 4:24 p.m.: 22 pages, French only. The Watcher agent captured it at 6:12 p.m. and opened change RC-2026-0418, and the Reader agent aligned English beside all 31 paragraphs, extracted 9 obligations and found the application date, March 31, 2027 (¶29). The impact map fans each paragraph out to the funds, policies, coded rule and owners it hits, each line labeled with its due date.
¶12, in English beside the French: “Managers run liquidity stress tests at least once a quarter for each fund, including a reverse scenario …”
- 046:31 p.m.
486 funds tested, and she asks why the money market funds are out
Applicability agentAgainst the fund master, 468 funds fall outside ¶5 because no Luxembourg-authorized manager runs them. Of the 18 Luxembourg funds, 14 sub-funds holding $49.3 billion are in scope and 4 are out: two money market funds (¶3), a closed-ended private equity fund (¶4) and a sub-fund that merges on November 30, 2026, before the application date (¶29). Priya asks the agents why the money market funds are out, and the answer quotes the French.
Applicability agent: “Euro Liquidity and USD Liquidity are money market funds under Regulation (EU) 2017/1131, and ¶3 excludes them … The Checker agent agreed on both.”
- 056:52 p.m.
The one fund the agents disagree on
Checker agentThe Checker agent re-tests all 486 calls with a separate model and agrees on 485. Private Credit Evergreen deals quarterly after a 24-month lock-up. The Applicability agent says open-ended and in scope at 92%, because investors can redeem before liquidation. The Checker puts it at 71%, citing the lock-up, the 5% dealing limit in the offering memorandum and ¶4's exclusion of closed-ended AIFs.
Checker agent: “I would not decide this alone.”
- 06Tuesday morning
She decides it, with a reason, and proposes to Legal
Priya Raman · Regulatory change managerPriya reads both arguments beside their sources, offering memorandum §8.2 and the EU definition of an open-ended AIF, and rules the fund in scope: “redemption rights before liquidation make it open-ended (¶5)”. Her reason goes to Legal with the proposal: 14 sub-funds in scope, 472 out, 2 policies and 1 coded rule. Acting as herself, she cannot approve it.
“Legal approves; you cannot approve your own proposal.”
- 07Approved
Legal approves, and four owners get dated actions
Eleanor Whitcombe · General CounselEleanor approves applicability with her reason: supported by ¶3, ¶4, ¶5 and ¶29. The Owner agent sends 5 actions to 4 owners from the responsibility map: Sophie Laurent's liquidity risk policy redline and first quarterly stress tests, Luc Reinert's liquidity management tools policy, Tomás Herrera's coded rule and Anne-Marie Weber's board paper for the management company. Policy due dates are the application date minus 33 days, the rule minus 16.
“5 actions sent to 4 owners · due March 31, 2027”
- 08The redline
Send her the redline, not the circular
Impact agentThe Impact agent searched 212 policies and 3,940 coded rules and traced ¶12 to §5.3 of the Liquidity Risk Management Policy – Luxembourg (LRM-LU v4.2). Its tracked changes move stress tests from semi-annually to once a quarter, add a reverse stress test that finds the redemption level at which a sub-fund can no longer meet requests, and report results to the board each quarter. Each insertion cites its paragraph; Sophie accepts, edits or rejects it with a reason.
Nothing changes in the policy library or the compliance engine until the owners act.
- 09Before go-live
The coded rule, tested in the sandbox first
Tomás Herrera · Compliance rule coding leadRule LQ-LU-117 goes from live version 7 to a version 8 drafted by the Impact agent: quarterly instead of semi-annual, a reverse scenario required, quarterly board reporting, and a scope of 14 sub-funds, 12 UCITS and 2 open-ended AIFs. Tomás runs it on Q3 2026 data in the compliance engine's sandbox: 13 pass and 1 alert, as expected, because Private Credit Evergreen has no reverse test on file yet.
“The engine keeps its own maker-checker: a second coder approves v8 before go-live.”
- 10Attestation
Done means proven, with the evidence attached
Sophie Laurent · Head of Risk, LuxembourgSophie's attestation has three steps: read the redline, attach evidence, attest. She links the published LRM-LU v4.3 and the board minutes of March 4, 2027 from the policy library, and the Checker agent confirms the published version matches the accepted redline. When she attests, action A-0418-1 closes and the evidence is kept 7 years.
Checker agent: “published v4.3 matches the accepted redline” — 3 of 3 insertions present, no other changes.