Some Approaching Deadlines
- 28 April 2017. Dedicated email address. The Central Bank has written to UCITS management companies, self-managed UCITS, AIFMs and internally managed AIFs requesting that they notify a dedicated e mail address in line with Fund Management Companies – Guidance by 28 April 2017 (this is earlier than the 30 June 2017 deadline indicated in the Guidance).
- 30 June 2017. Sub-Fund Profiles. Deadline for filing the Investment Funds Annual Sub-Fund Profile Return on the Central Bank's ONR.
- 13 July 2017. SFTR. Deadline for prospectus/supplement updates to include disclosures under the Regulation on reporting and transparency of securities financing transactions (SFTR). Umbrella investment funds which use Securities Financing Transactions (SFTs) and total return swaps and which have been authorised since 12 January 2016 should have the requisite disclosures in their prospectus. Sub-funds have until 13 July 2017 to update their prospectus or supplement. UCITS and RIAIFs should allow sufficient time for the Central Bank to review documentation in advance of the deadline.
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 end.
Irish Funds Guidance Paper 6 on Investment Restriction Breaches, Pricing Errors, Compensation and Reporting
Irish Funds have revised Industry Guidance Papers 6 and 8 and compiled these into one Guidance Paper which has now been recast as Guidance Paper 6. This Guidance Paper relates to investment restriction breaches, pricing errors, compensation and reporting.
Updated Guidance Paper 6 has not changed existing industry principles or guidelines and compensation will continue to be predominately applicable to advertent breaches and errors in excess of 50bps. The requirements of the Central Bank of Ireland (Central Bank) in respect of the notification of pricing errors and breaches have been reflected in the update. In addition, the updated Guidance Paper introduces additional approval requirements in respect of the application of the ‘alternative compensation arrangements’ for advertent investment restriction breaches (in practice, these are used in a very small number of cases). Please speak with your usual contact in the A&L Goodbody Asset Management & Investment team if you would like a copy of the Guidance Paper.