Some Approaching Deadlines
- 25 August 2016. CP86 – Third consultation paper. CP86 – Third consultation paper closes on 25 August 2016. Please see our InFocus document for more detail.
- 25 August 2016. CP105- Consultation on amendments to the Central Bank UCITS Regulations. CP105- Consultation on amendments to the Central Bank UCITS Regulations closes on 25 August.
- 1 September 2016. Companies Act 2014. The majority of the Companies Act 2014’s provisions commenced on 1 June 2015 (Commencement Date). If a UCITS management company (UCITS ManCo) or AIFM (or s.110 subsidiary) is converting to a company limited by shares (CLS), the shareholder(s) of the UCITS ManCo or AIFM (or s. 110 subsidiary) must pass a special resolution to adopt a new constitution, which must be filed with the Irish Companies Registration Office (CRO) by 30 November 2016. If the UCITS ManCo or AIFM (or s. 110 subsidiary) is converting to a designated activity company (DAC), the shareholder(s) of the UCITS ManCo or AIFM (or s. 110 subsidiary) must pass an ordinary resolution resolving that the company be registered as a DAC by 1 September 2016. Variable Capital Companies may choose to update their Memorandum and Articles of Association to reflect the provisions of the Companies Act 2014 and other regulatory changes when planning their Annual General Meetings. Please see our In Focus document for more detail.
- 1 September 2016. FSB consultation on recommendations to address structural vulnerabilities arising from asset management activities. The FSB consultation on recommendations to address structural vulnerabilities arising from asset management activities closes on 1 September 2016.
- 23 September 2016. ESMA Call for Evidence on Asset Segregation and Custody Services under the AIFMD and the UCITS Directive.The ESMA Call for Evidence on Asset Segregation and Custody Services under the AIFMD and the UCITS Directive closes on 23 September 2016 (as detailed below).
- 2 October 2016. EU consultation on cross-border distribution of investment funds. European Commission consultation on the capital markets union action on cross-border distribution of investment funds (UCITS, AIFs, ELTIFs, EuVECAs, EuSEFs) across the EU closes on 2 October 2016.
- 1 November 2016. Redemption Gates. Deadline for existing UCITS to remove provisions whereby redemption requests carried over from a prior dealing day as a result of the application of a gate receive priority. Many UCITS provide for priority rights of redemption for investors on subsequent dealing days in respect of the balance of redemption requests that had been subject to a gate. The Central Bank believes that applying priority to redemption requests which have been subject to a gate may materially prejudice investors, particularly small investors. This is notwithstanding the fact that the original gate would have had to have been applied pro rata to all investors, large and small, who had submitted redemption requests. This change (which will likely require a change to the UCITS' constitution) should be completed by all UCITS by 1 November 2016.
This list does not cover ad hoc filings (such as regulatory reports) or filings of annual accounts (and related documents which include annual FDI Return) and semi-annual accounts because these dates will vary to reflect the particular year ends.