Following on from the Central Bank of Ireland's
("Central Bank") Dear Chair Letter
issued on 20 October 2020, which set out the Central Bank's
findings following its thematic review of the implementation of its
Guidance for Fund Management Companies (known as CP86), fund
management companies ("FMCs") are now
working on the action plans required to be discussed and approved
by boards by the end of March 2021.
The Central Bank letter called on all FMCs (including
self-managed investment companies or SMICs), whether or not the FMC
has received a risk mitigation programme from the Central Bank, to
critically assess their day to day operational, resourcing and
governance arrangements against all relevant rules and guidance,
taking into account the findings of the Central Bank's thematic
review. For an overview of the findings in the Central Bank's
letter, see our earlier update here.
