The Central Bank of Ireland (Central Bank) has responded positively to a request from industry that the operational date for the IMR should be delayed from 1 April 2016 until 1 July 2016. The Central Bank is engaged in the process required by law to effect this change including consultation with the Minister for Finance. Many investment funds (but not all) will be changing their processes to ensure that their subscription/redemption/dividend accounts operate at an umbrella level as fund assets and so are not subject to the Investor Money Regulations (which will be effective from 1 July 2016).
ESMA Q&A gives detail on the timing of documentation updates for the remuneration and depositary requirements of UCITS V
The European Securities and Markets Authority (ESMA) published a new Q&A document on the application of the UCITS Directive, as most recently revised by UCITS V.
The Q&A includes the following new Q&A on the documentation updates which UCITS funds need to provide to meet the remuneration and depositary requirements of UCITS V. The new Q&A also repeals and replaces four Q&A's on UCITS that ESMA has previously issued.
UCITS V Delegated Regulation on the obligations of depositaries
The Council of the EU published a press release reporting that the Council decided not to object to the Delegated Level 2 Regulation supplementing UCITS V on the obligations of depositaries. The regulation was previously adopted by the European Commission and will enter into force, unless the European Parliament objects.