Funds Bulletin

March 2015

The Deloitte Funds Bulletin delivers you our latest updates and insights on industry developments. We hope you find this edition useful and please contact us if you have any queries.

EBA Guidelines on Remuneration

On 4 March 2015, the European Banking Authority (EBA) published a consultation paper (Consultation Paper) on its draft Guidelines on sound remuneration policies (Guidelines)

The Guidelines provide guidance on the remuneration principles set out in the Capital Requirements Directive (CRD IV). They affect credit institutions and investment firms (ie, firms that fall within the scope of the Markets in Financial Instruments Directive (MiFID), including all their subsidiaries - even if those subsidiaries are not themselves subject to the CRD IV framework. They require those institutions to apply sound remuneration policies to all staff, and to impose specific requirements for the variable remuneration of staff whose professional activities have a material impact on the institutions’ risk profile (Identified Staff).

MMF Regulation

On 12 March 2015, the European Parliament's Committee on Economic and Monetary Affairs (ECON) published its report (Report) on the Money Market Funds Regulation (MMF Regulation) following their vote on 26 February 2015. The Report appended the latest version of the MMF Regulation, whose key terms concern Constant Net Asset Value (CNAV) MMFs, calculation of the net asset value (NAV), the use of amortised cost, authorisation, and additional investor protection measures. 

ICAV: Enacted and in action

The ICAV Act 2015 became operational on 12 March 2015, followed just days later by the launch of Ireland’s first fund structure using an ‘Irish Collective Asset-management Vehicle’ (ICAV). The ICAV is a bespoke funds vehicle which incorporates the key features of Ireland’s existing funds vehicles to create a flexible and efficient structure.

ELTIF: Advent of a two tier Europe?

The European Long-term Investment Fund (ELTIF) is a new fund structure aimed at promoting sustainable long-term investment in the European economy. Its focus is on investment in long term projects including infrastructure, loans, real assets, sustainable energy, and new technologies.

As ELTIFs are available to both retail and institutional investors, they potentially herald the advent of a two-tier alternative fund regime in Europe: AIFs which are pass-portable to professional investors under AIFMD, and ELTIFs which may also be passported under AIFMD to retail investors.

NEW! Link'n Learn webinar: Loan Funds

Led by Deloitte’s industry experts, Link’n Learn is a series of free of charge webinars conducted during the course of the year, specifically designed to keep you up-to-date with today’s critical trends and the latest regulations impacting your business. An hour of your time is all you need to log on and tune in to each informative webinar.

Join our latest webinar in the series: Loan funds

Coming up:
AML Webinar – 16 April 2015
European fund distribution – 30 April 2015


Client Asset and Investor Money Regulations

On 30 March 2015, the Central Bank of Ireland (CBI) issued two sets of regulations: Client Asset Regulations and Investor Money Regulations (Regulations). The CBI also published guidance for Investment Firms and guidance for Fund Service Providers to assist industry in interpreting the Regulations.

Questions and Answers: Application of the AIFMD

On 26 March 2015, ESMA published two revised ‘Questions and Answers’ documents; an updated ‘Q&A on Key Investor Information Document (KIID) for UCITS’ (KIID Q&A) and an updated ‘Q&A on the Application of the AIFMD’ (AIFMD Q&A).

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