Central Bank Publishes Revised UCITS Q&A And Q&A On AIFMD

Background

In October 2020, the Central Bank of Ireland ("CBI") published a Dear Chair Letter to Irish regulated UCITS management companies, AIFMS, self-managed UCITS funds and internally managed AIFS ("Management Companies") in which it required all Management Companies to critically assess their operations to identify the steps necessary to ensure that they meet the Central Bank's expectations in a number of areas, including resourcing¹. The Dear Chair Letter confirmed that all Management Companies must have a minimum of 3 full time employees, each of whom should be "suitably qualified and of appropriate seniority to fulfil the role".

In response to the Dear Chair Letter, many self-managed UCITS funds and internally managed AIF funds have taken the decision to convert to an externally-managed fund, in many cases engaging a third party management company² to act as manager to the relevant fund.