Central Bank Publishes CP86 Review Findings

The Central Bank communicated its findings ("Findings") in an industry letter that all fund management companies (including self-managed investment funds) ("FMCs") should use to "critically assess" their operating models and resourcing and governance arrangements. In addition, the Central Bank is issuing a number of risk mitigation programmes to certain FMCs. However, the Central Bank expects all FMCs to review the issues identified in the Findings and to develop and progress individual action plans to address these issues and meet the Central Bank's expectations. These actions plans must be approved by the board of directors of the FMC by the end of Q1 2021. The most significant findings relate to substance and governance. The Central Bank has stated that all FMCs should have a minimum of 3 FTEs (full-time employee or equivalent to full time employee) and should appoint locally based Designated Persons ("DPs") and other staff who have sufficient time to dedicate to