- 21 December 2014, Reliance on Credit Ratings - Regulations 3 (c) and 5 of The European Union (Alternative Investment Fund Managers) (Amendment) Regulations 2014 (SI 379/2014) shall come into operation. Regulations 3 (c) and 5 transpose the requirements of the Credit Ratings Agencies Directive aiming: (i) to restrict the reliance on ratings provided by credit rating agencies, (ii) to refine the requirements for risk management and (iii) to amend the AIFM Regulations and the UCITS Regulations accordingly (as detailed in the August Front Page).
- 31 December 2014, Corporate Governance – Reviews of board and individual director performance must be completed by year end.
- 31 December 2014, 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 confirmation from persons performing PCFs (e.g. directors) and CFs (e.g. Money Laundering Reporting Officer (MLRO) and Company Secretary). The filing deadline for submitting the Annual PCF Confirmation Return via the Central Bank's Online Reporting System has not yet been notified by the Central Bank (the filing deadline to cover 2013 confirmations was 28 February 2014). New regulations prescribing six new PCFs (which include chief operating officer for all RFSPs, head of client asset oversight for investment firms and head of investor money oversight for financial service providers) shall come into effect on 31 December 2014 and prior Central Bank approval will be required for appointments to any of these new PCFs from 31 December 2014.
- 31 December 2014, Anti-Money Laundering/ Counter Terrorist Financing (CTF/AML) - Collective investment schemes and management companies should be aware of the regulatory expectation that their boards be offered training on the law relating to AML/CTF 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/CTF policy and where the board has adopted such a policy, that it receives appropriate confirmations from relevant persons.
- 31 December 2014, 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 2014, FATCA - 31 December 2014; FATCA - Reporting Irish Financial Institutions are required to register with the United States Internal Revenue Service (IRS) to obtain a Global Intermediary Identification Number (GIIN) by no later than 31 December 2014.
- 30 January 2015, ESMA consultation, closing date for submissions in respect of the ESMA consultation on guidelines on asset segregation under the AIFMD (see below).
- 17 February 2015, Discussion Paper on Regulatory Technical Standards (RTS) for RIIPs KID, closing date for submissions (see November Front Page).
- 19 February 2015, UCITS KIID - 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.
This list does not cover ad hoc filings (such as regulatory reports), AIFMD reporting, EMIR reporting, Revenue filings, Minimum Capital Requirement Reporting 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.