Additional Pre-Approval Control Functions And The Impact On The Asset Management Industry

As readers will recall from our article in April 2019 the Central Bank of Ireland (the "CBI") has a continued focus on fitness and probity. Pursuant to this, the CBI issued a notice of intention on 25 February, 2020 (the "Notice") proposing to:

• Introduce three new Pre-Approval Controlled Functions ("PCFs"):
  • Chief Information Officer PCF-49 (under the 'General' category);
  • Head of Material Business Line PCF-50 (under the 'Banking' category);
  • Head of Market Risk PCF-51 (under the 'Banking' category);
• Split PCF-39 Designated Person into six PCF roles aligned to the specific managerial functions.

The introduction of the new PCF roles under point one above will result in further individuals falling under the CBI's purview with respect to whether they are fit and proper in relation to the specific PCF role they are carrying out in their firm. The CBI referenced in the Notice that the introduction of these roles is on the basis of (i) the increasing