Central Bank Issues "Dear Chairman" Letter Regarding Directors' Time Commitments for Each Sub Fund

The Central Bank of Ireland issued a “Dear Chairman” letter on 8 September 2016, concerning its review of the number of directorships held by Individuals within the Investment Funds Industry. The Central Bank found that the amount of time allocated by directors annually to sub-funds varied significantly from 2 hours to 11 hours per sub-fund.

Read the letter in full here.

Central Bank Releases 14th UCITS Q&A

The Central Bank has released its latest update to the UCITS Q&A. The fourteenth update contains updates mainly concerning account submissions and umbrella cash accounts. In respect of umbrella cash accounts, the central bank confirmed that:

• Its guidance in respect of umbrella cash accounts did not apply to cash accounts established at the sub-fund level of an umbrella fund.
• It is possible to establish more than one umbrella cash account at the level of the umbrella fund.
• An umbrella cash account cannot be opened for more than one umbrella fund.

Read the UCITS Q&A in full here.

Central Bank: Organisational Update

Governor of the Central Bank, Philip Lane, has proposed to split the Central Bank’s key markets supervision division into two units as it deals with a surge of enquiries from London-based investment funds and firms following the Brexit referendum.

The proposed change includes the establishment of two new directorates to replace the current Markets Supervision Directorate; an Asset Management Supervision Directorate (AMSD) and a Securities and Markets Directorate (SMD). Recruitment for the head of each division has commenced.

This will be the Governor’s first major organisational overhaul since he took over the helm of the Central Bank last November. Staff were told about the restructure late last week.

Central Bank Issues Cross Industry Guidance in Respect of Information Technology and Cybersecurity Risks

The Central Bank issued a guidance paper on 13 September 2016, setting out the Central Bank’s guidance in relation to information technology and cybersecurity governance and risk management by regulated firms in Ireland.

The risks associated with IT and cybersecurity are a key concern for the Central Bank given their potential to have serious implications for prudential soundness, consumer protection, financial stability and the reputation of the Irish financial system. Accordingly, the Central Bank expects that the Boards and Senior Management of regulated firms fully recognise their responsibilities in relation to IT and cybersecurity governance and risk management and place these among their top priorities.

The guidance paper can be read in full here.