The Investor Money Regulations concern fund service providers holding investor money in collection accounts and by virtue of Amending Regulations, the Investor Money Regulations will be effective from 1 July 2016 (See amending regulation).
The Central Bank has also published Guidance for Fund Service Providers to assist Industry in interpreting the regulations.
On 5 October 2015, the Central Bank published the first edition of the Investor Money Q&A.
The Investor Money Regulations Q&A sets out answers to queries likely to arise in relation to the implementation of the Investor Money Regulations.
Many (but not all) investment funds 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 IMR as detailed in Central Bank Guidance on umbrella funds - cash accounts holding subscription, redemption and dividend monies.
- The General Principles.
- When it is not appropriate to operate an umbrella cash account.
- Policies and procedures (these should be agreed with the depositary to govern the operation of an umbrella cash account and should be reviewed by both parties, at least annually).
- Disclosure to investors.
- Treatment of subscription, redemption and dividend monies in umbrella cash accounts.
- Insolvency of one sub-fund within an umbrella fund the general.