The Central Bank issued guidance on operating an umbrella fund cash account  for subscriptions and redemptions, which are considered fund assets (and so not subject to Investor Money Regulations).  This guidance provides information on:

  • general principles;
  • policies and procedures that should accompany such an account;
  • disclosures that should be made to investors;
  • treatment of subscription, redemption and dividend monies; and
  • insolvency of one sub-fund within an umbrella fund.

Funds adopting this approach will be reviewing their constitutions and prospectus disclosures in advance of the 1 April 2016 deadline.