- 31 December 2013;Corporate Governance – Completion of reviews of board and individual director performance.
- 31 December 2013;Fitness & Probity - Collective investment schemes, management companies and other regulated financial service providers (RFSPs), where they have not already done so, will need to obtain their annual certification from persons performing PCFs (e.g. directors) and CFs (e.g. Money Laundering Reporting Officer (MLRO) and Company Secretary) that they are aware of the fitness and Probity standards, agree to continue to abide by those standards and will notify the RFSP if they no longer comply. An annual PCF Audit Confirmation is required for submission via the ONR system by 28 February 2013 (see below).
- 31 December 2013; Anti-Money Laundering (AML) - Collective investment schemes and management companies should be aware of the regulatory expectation to offer training to their boards on the law relating to AML and counter terrorist financing on an annual basis (and at such other times as may be appropriate). Boards should also ensure that they have considered whether to adopt a board level AML policy and where the board has adopted such a policy, that it receives appropriate confirmations from relevant persons.
- 31 December 2013; Business plan - UCITS management companies and Self-Managed Investment Companies (SMICs) - UCITS management companies and SMICs, where they have not already done so, may need to obtain annual confirmations from service providers and relevant persons in accordance with their business plans.
- 31 December 2013l;Online Reporting System (ONR) - Irish authorised investment funds and their service providers might usefully consider whether the appropriate person has been appointed as system administrator and whether the appropriate delegations have been made. As mentioned above, an annual PCF Audit Confirmation is required for submission via the ONR system.
- 1 January 2014;UCITS management companies and AIFMs must meet CRD IV requirements on initial capital, own funds and fixed overheads from this date.
- 12 February 2014; EMIR reporting to trade repositories commences.
- 19 February 2013; Annual update of the key investor information document (KIID) must be filed no later than this date (where required). Any update to the KIID filed with the Central Bank must be translated (as necessary) and filed in any other host jurisdictions where the UCITS is registered to market its shares and uploaded on the UCITS' website.
- 21 February 2014;latest date for receipt of applications seeking authorisation as AIFM (including internally managed AIF) and for applications to act as Registered AIFM (where applicants assets under management are below the thresholds set out in Regulation 4 of the AIFM Regulations).
- 25 April 2014;Date to be registered for FATCA.
- 2 June 2014;IRS publish list of participating foreign financial institutions (FFIs) for FATCA purposes.
- 1 July 2014;FATCA withholding start date for FDAP (annual/periodical) payments).
- 22 July 2014; End of transitional period for EU AIFM, Non-EU AIFM can continue to market both EU and non-EU AIF to professional investors– additional reporting obligations apply.
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