The Investor Money Regulations (IMR) are due to come into effect on 1 April 2016.  IMR relates to collection (subscription and redemption) accounts operated by fund services providers (FSPs), which include UCITS management companies, AIFMs, fund administrators and depositaries. Many FSPs that would otherwise come within the ambit of IMR are working with their fund promoter clients to establish a model for collection accounts such that they are held in the name of the fund (thus regarded as fund assets) and consequently fall outside the scope of IMR.  There is considerable detail around this model which is currently being worked out between FSPs and fund promoters.  A senior official in the Central Bank recently indicated publicly that, in the interests of establishing an enduring regime for the protection of investors, the Central Bank would be supportive of a delay of a number of months in the commencement of IMR.  This would require an amendment to the legislation but we expect that there will be a delay of about three months (to 1 July approximately) to the commencement of IMR.