The head of the function has left. The work continues every day and someone has to answer for it.
The deputy knows the technical side. What is missing is exposure, not ability.
The visit is done and the report is not in yet. That window is useful, and it is open now.
The team needs to see continuity quickly.
The mandate
Hold the seat. Be a steady, available counterpart for the CSSF, the board and the AIFMs while the search runs.
Work through the report. Read it properly, agree what it means, turn it into a clear plan with owners and dates.
Keep communication continuous with the other authorized managers and leadership. No gap in the reporting line.
Bring the deputy up. Technical depth on one side, and the skills the seat actually needs on the other.
Why this fits: the record
Already fit and proper, approved by the CSSF as conducting officer and as board member
23 years at CACEIS across custody and depositary, then Standish
A €30 billion credit fund: remediation led across central administration, custody and depositary
2017: identified a €300 million fraud and made the reports to the CSSF and to the FIU
Why this fits: the succession
Built and delivered internal audit action plans on depositary and fund administration at CACEIS
At CACEIS I brought my own deputy to the level where he could take my role
In executive coaching training since December, so the support side is structured rather than improvised
PASCAL HERNALSTEENDEPOSITARY · THE BRIEF
Phase 01
30
DAYS
Diagnose.
Get the regulatory footing in place and understand the function properly.
Regulatory footing
File my conducting officer approval with the CSSF in the first week
Notify the interim arrangement
The inspection file
Read the full file: announcement letter, documents provided, interview notes, closing meeting
The function
Review the depositary procedures and policies against Circular CSSF 18/697 and AIFMD Article 21
Cash flow monitoring, ownership verification and records, safekeeping, oversight duties, delegate due diligence
The people
Meet the other authorized managers, compliance, risk, internal audit and the board sponsor. Agree how we work together
Meet the team. Understand the workload, the client book and where the pressure sits
Sit with the deputy. Agree what they already carry and where they want support
At Day 30
A written picture of the function, my own reading of what the report may cover, the CSSF approval file submitted, and a meeting rhythm in place with the team and with leadership.
PASCAL HERNALSTEENDEPOSITARY · DAY 1–30
Phase 02
60
DAYS
Plan.
Turn the report into an agreed plan and start working through it.
Read it together
Read the report with compliance and the other authorized managers
Agree what each point means before we answer
Draft the response
Point, cause, action, owner, date
And the evidence that will show it is done
Prioritise
Sort the actions on an Eisenhower matrix
Urgent and important first, important and not urgent scheduled, the rest visible without driving the plan
Govern it
Take the plan through the board, then to the CSSF
A short working meeting on the plan, minutes, and a monthly point to the board
Start the mentoring: the deputy drafts, we review together, they attend every CSSF exchange
At Day 60
Response and plan agreed with the board and shared with the CSSF, follow-up meetings running and minuted, first actions completed, development plan agreed with the deputy and the board.
PASCAL HERNALSTEENDEPOSITARY · DAY 31–60
Phase 03
100
DAYS
Deliver.
Work through the plan and prepare the handover.
Close the actions
Complete the actions one by one, with the supporting evidence filed as we go
Have compliance or internal audit look at a sample before we report anything as done
Fix the design
Where a point touches the design and not only the case, fix the design
Report
Report progress to the CSSF at the agreed rhythm
Hand over
Let the deputy lead the follow-up meeting and speak first in the room
Prepare the handover: the control picture, the action tracker, the CSSF correspondence file, the board pack
At Day 100
The important actions closed with evidence, progress reported to the CSSF with deadlines respected, the successor’s case documented, and a handover pack that does not depend on me.
PASCAL HERNALSTEENDEPOSITARY · DAY 61–100
How I work
Working together.
With the CSSF
One named contact who answers and knows the file
They hear anything material from us first
Dates I commit to are dates I hold. I would rather ask for more time than miss
Anything we report as done is supported by a document
The plan is owned and signed by the board, so it holds after I leave
With the authorized managers and leadership
A weekly team meeting on the depositary function, with a short written record
A standing point with the other authorized managers, so the collegial body works and decisions are shared
Attendance at leadership meetings and a monthly written update to the board
An agreed escalation route, so nothing waits for my next day on site
Cover arranged with the other authorized managers for the days I am not on site, and written down
What I would need
The complete inspection file at the start, including the closing meeting notes
A named board sponsor and a place on the board agenda
Clear authority to sign and to escalate
Protected time for the deputy’s development, away from production
The plan owned as a board document
The point I want to raise myself
The CSSF looks at the time a conducting officer gives to the role and at their other commitments
A part-time interim is better presented up front than explained later
Fixed named days on site rather than “when available”, reachable outside those days for anything regulatory
Documented cover with the other authorized managers
Described to the CSSF as a deliberate interim, with an end date and a successor track
PASCAL HERNALSTEENDEPOSITARY · WORKING TOGETHER
Succession
Bringing the deputy up.
The ramp
Day 1 to 30: I do the work, they observe, we debrief each week
Day 31 to 60: they draft, I review, they attend every CSSF exchange
Day 61 to 100: they lead, I support, they speak first in the room
The technical side
The depositary duties
The procedures
The files
The regulatory reading
The rest
How to run a meeting
How to write to a regulator
How to sit with peers as an equal
How to lead the team
Throughout
Agreed objectives
Monthly review with the board sponsor
An honest view on readiness
The point
Technical depth on one side, and on the other the skills the seat actually needs. The deputy knows the technical side already. What is missing is exposure, not ability.