Financial Services Regulation and Compliance - Funds Sept 2020
CBI deadlines for Christmas 2020
The CBI issued its Christmas deadlines for receipt of applications for:
- fund and sub-fund applications that have pre-Christmas or pre year-end approval deadlines including self-managed/internally managed investment company/ICAV applications
- approval of post-authorisation amendments that have pre-Christmas or pre year-end approval or noting deadlines
Investment Limited Partnerships (Amendment) Bill 2020
The Investment Limited Partnerships (Amendment) Bill 2020 (the ILP Bill) has been published and is now progressing through the legislative process. It is expected to be enacted soon.
Update of the ICAV Act 2015
The ILP Bill will make some amendments to the ICAV Act 2015.
Register of beneficial ownership of ILPs and CCFs
The ILP Bill will introduce beneficial ownership rules for ILPs and CCFs.
CBI expects full compliance on liquidity stress testing in UCITS and AIFs from 30 September 2020
The CBI expects full compliance with the ESMA Guidelines on liquidity stress testing in UCITS and AIFs from 30 September 2020.
SFTR: Reporting for Investment Funds from 11 October
The Securities Financing Transactions Regulation imposes reporting obligations on counterparties on a phased basis. The reporting on UCITS and AIFs with authorised/registered AIFMs will commence on 11 October 2020, with the UCITS Management Company or AIFM being responsible for reporting on behalf of the UCITS or AIF.
CBI Money Market Fund Regulation Reporting Guidance Note
On 31 August 2020, the Central Bank published a Guidance Note on Money Market Fund Regulation Reporting.
EU & INTERNATIONAL
UCITS Directive and AIFMD revision proposals for digital operational resilience
The EU Commission proposed a digital finance package that includes a draft directive (which will update the UCITS Directive and AIFMD) on digital resilience and a draft regulation on digital operational resilience (DORA).
ESG: prospectus and FS disclosure templates
The European Supervisory Authorities (ESA's) issued the following mock-ups of the prospectus and financial statement ESG disclosure templates for so-called "light-green" or Article 8 and "dark-green" or Article 9 products in the form of a survey and asked for feedback by 16 October 2020.
For more information on these topics please contact any member of A&L Goodbody's Financial Regulation team.
Date published: 7 October 2020