The Central Bank is currently considering the fine detail of its requirements for SMIC business plans so as to ensure pragmatic and proportional compliance by SMICs with the organisational rules in Level 2 of the UCITS IV Directive. While UCITS management companies and self-managed investment companies (SMICs) are subject to the same regime, the structures necessary to ensure compliance will differ for SMICs because of the simpler nature of a SMIC. For example, SMICs will be exempt from the requirement to have a permanent compliance function and a permanent internal audit function. The organisational requirements introduced by UCITS IV apply to both management companies and SMICs. They involve documented operating, administrative and accounting policies and procedures and these are, in turn, reflected in business plans. Areas amplified include internal control mechanisms, lines of responsibility, internal audit, conflicts of interest, rules of conduct (to ensure ongoing fair treatment of investors), best execution policies, complaints procedures, data protection procedures and compliance functions. The principle of proportionality is provided for so that, for example, compliance is easier for a smaller UCITS SMIC than for a multi-jurisdictional manager with multiple UCITS under management. UCITS IV did not provide for the adoption by the EU Commission of level 2 implementing measures in respect of SMICs and this is now being considered as part of UCITS VI. UCITS VI is the name given to the Commission's recent consultation document entitled ‘UCITS – Product Rules, Liquidity Management, Depositary, Money Market Funds, Long-term Investments' which explores whether the application of the organisational rules to SMICs may be addressed as part of the UCITS VI Directive. This consultation was detailed in the August Front Page.