An information note has been prepared with the agreement of the Central Bank detailing provisions regarding the treatment of subscriptions and redemptions under UCITS IV and specifying how the relevant requirements for recording and handling subscription and redemption orders can be met.
The issue arose as the Central Bank’s (revised) UCITS Notice 2 requires Management Companies to record certain information in relation to subscriptions and redemptions, including the date and time of receipt of the order. However, while this requirement is currently applicable to all UCITS management companies, following previous guidance from the Central Bank, it appeared to be inapplicable to self managed investment companies ("SMICs‟) at present and only to apply to them from July 2013.
However, there is a separate requirement in UCITS Notice 16 for the date and time of receipt of subscription or redemption orders to be included on the contract note issued to an investor and this is currently applicable to both SMICs and UCITS management companies. Accordingly the new information note reconciles these apparently inconsistent requirements and provides guidance on how UCITS or their service providers may comply with the relevant requirements on receipt of orders and issuance of contract notes to investors.