Financial Services Regulation and Compliance - Funds Nov 2019

Domestic 

Irish Practice Developments November 2019

CBI Review of CP86 implementation- phase 3

The Central Bank of Ireland (CBI) has commenced phase 3 of its assessment of the implementation by fund management companies of CP86 Fund Management Company Guidance. As anticipated, phase 3 involves on-site inspection which, like phase 2, is generally focused on the fund risk management, investment management oversight and OE roles.

CBI Asset Management supervision priorities for 2020

Michael Hodson, CBI Director of Asset Management and Investment Banking confirmed that CBI supervision work will continue in 2020 across a number of areas including but not limited to:

  • the thematic review on fund management company effectiveness
  • consultation work on errors in investment funds
  • liquidity risk and leverage
  • engagement meetings and full risk assessments

Brexit - UK TPR

Following the recent extension to Brexit until 31 January 2020 the UK FCA has extended the deadline for notifications under the temporary permissions regime (TPR) to the end of 30 January 2020.

European 

EU & International Developments: November 2019

ESMA speech on fund liquidity

Steven Maijoor, chairman of ESMA, delivered a speech on fund liquidity at EFAMA’s Investment Management Forum.

Amendment of PRIIPs Delegated Regulation to align transitional arrangements

Commission Delegated Regulation (EU) 2019/1866 amends the PRIIPs Delegated Regulation to align the transitional arrangements for PRIIP manufacturers offering units of UCITS and non-UCITS funds (referred to in Article 32 of the PRIIPs Regulation) as underlying investment options. It extends the transitional arrangements by two years, to 31 December 2021. It entered into force on 28 November 2019.

Brexit

Following the recent extension to Brexit until 31 January 2020. ESMA confirmed that previous statements about its preparations for a no-deal Brexit on 31 October 2019 no longer apply. ESMA will issue further announcements and updated measures as matters develop.

For more information on this topic please contact any member of A&L Goodbody's Financial Regulation team.

Date published: 15 November 2019