Central Bank Issues Feedback Statement On CP86 And Final Guidance On Fund Management Company Effectiveness

Bringing to a conclusion its 3 year consultation process on Fund Management Company effectiveness, the Central Bank yesterday published its feedback statement on CP86 together with final guidance. CP86 applies to fund management companies ("FMCs"), which include self-managed UCITS and QIAIFs as well as UCITS management companies and AIFMs, which are authorised by the Central Bank.

The feedback statement marks a softening of the Central Bank's original position set out in the consultation, in particular the location of EEA resident directors/designated persons, which has been reduced from two thirds to 50%; a relaxation of the Irish residency requirement for designated persons and a longer timeframe for implementation. The feedback statement has widely been welcomed by industry and provides greater certainty to managers post-Brexit. We set out below a summary of the key points in the feedback statement.