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ARTICLE · 14 JANUARY 2022

CBI Clarifies Expectations On Non-Discretionary Investment Advisors

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On 20 December 2021, the Central Bank of Ireland ("Central Bank") issued the 44th edition of its AIFMD Q&A and the 36th edition of its UCITS Q&A (together the "Q&As").

IrelandFinance and Banking
Eimear O'Dwyer
Eimear O'Dwyer
Caitriona Carty
Caitriona Carty
Stephen Carty
Stephen Carty
Ian Conlon
Ian Conlon
Ronan Cremin
Ronan Cremin
John Gallagher
John Gallagher
Philip Keegan
Philip Keegan
Deirdre McIlvenna
Deirdre McIlvenna
Aaron Mulcahy
Aaron Mulcahy
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On 20 December 2021, the Central Bank of Ireland ("Central Bank") issued the 44th edition of its AIFMD Q&A1 and the 36th edition of its UCITS Q&A2 (together the "Q&As").

Among the updates included in the AIFMD Q&A is a new Q&A on the use of non-discretionary investment advisors.  This clarifies the Central Bank's expectations on arrangements for a Qualifying Investor AIF ("QIAIF") involving a non-discretionary investor advisor ("Advisor"), where the Advisor receives a higher proportion of fees than other service providers to the QIAIF.

This is of particular interest to any firm managing (or considering the establishment) of a QIAIF with a private equity strategy or otherwise investing in physical assets which do not qualify as financial instruments, and which will rely on the services of Advisors. 

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