Following publication by ESMA of its final guidelines on
liquidity stress testing in UCITS and AIFs (the "ESMA
Liquidity Guidelines") on 2 September 2019 (see our briefing
available
here) and recent industry communications issued by the Central
Bank, it is clear that fund liquidity is set to remain a regulatory
and supervisory priority at both domestic and EU level over the
coming months.
In its letter issued on 7 August 2019, the Central Bank reminded
industry that responsibility for liquidity risk management, which
includes compliance with all legal and regulatory obligations in
respect of the liquidity of each fund under management, rests with
the boards of fund companies (funds and fund management companies
(including self-managed investment companies)), individual
directors and the relevant designated persons.
