Central Bank of Ireland announces UCITS liquidity questionnaire

CBI UCITS liquidity questionnaire

The Central Bank of Ireland (CBI) contacted certain Irish UCITS fund management companies and Irish UCITS on 6 February 2020 to advise that a detailed UCITS liquidity questionnaire will become available for completion in March 2020. Recipients of the questionnaire will have about 3 weeks to complete it. The CBI included the template liquidity questionnaire in its communication and asked that it is shared with all board members.

ESMA common supervisory action on liquidity

This is stage 1 of the common supervisory action with national competent authorities on UCITS liquidity risk management announced by ESMA on 30 January 2020. The ESMA press release and the CBI communication both describe 2 stages of the assessment. Stage 1 is the request for information and quantitative data, to be provided by completing the liquidity questionnaire. Stage 2 will involve focussing on a sample of UCITS managers and UCITS to carry out more in-depth supervisory analyses.

CBI expectations

The CBI, referring to its previous correspondence of 7 August 2019, repeated that the responsibility for liquidity risk management, including compliance with all legislative and regulatory obligations, rests with the board of the fund management company, the individual directors and the relevant designated persons. The liquidity questionnaire will be available to complete in March 2020 only via the CBI's ONR system. As the CBI is providing the content of the questionnaire in advance of the start of the reporting window, we can expect that there will be a hard submission deadline date.

Recommendations for Irish UCITS

UCITS management companies who have received the questionnaire will need to advise their Irish UCITS under management. The CBI communication and questionnaire should be brought to the attention of all board members of UCITS and UCITS management companies in scope of the liquidity review.  The process of compiling data should begin as soon as possible in preparation for completion of the questionnaire via the CBI's ONR system when the reporting window opens in March 2020.

For more information in relation to this topic please contact any member of the A&L Goodbody Asset Management & Investment Funds team.

Date published: 6 February 2020