Investor Money Regulation
June submission required
The Central Bank of Ireland has recently contacted Fund Service Providers that have confirmed that they will hold Investor Money, OR, have not yet confirmed their position, to advise them that they are required to submit to the Central Bank, by 30th June 2016, a detailed description as to how they will comply with the Investor Money Regulations from 1st July onwards.
The Investor Money Management Plan is required to be completed within three months of the 1st July, but firms will need to consider the following when responding to this new request from the Central Bank:
- What is the operating model and how is it designed to comply with the Regulations?
- How can the operating model be illustrated to the CBI?
- What controls are in place around manual activity?
- Who is the Head of Investor Money Oversight, what is their role and what resources do they have available to them?
- Who has been appointed to perform the annual investor money audit?
- What are the materiality thresholds that the business has considered to comply with its reporting obligations to the CBI?
With a very tight deadline and some outstanding issues at an industry level e.g. the treatment of money flowing through a recognised clearing system and the treatment of rebates and retrocessions, firms will need to act fast to ensure that they can demonstrate that they have considered all relevant activity.
How we can help
We have worked with a number of firms to prepare for the implementation of these new rules and are very aware of the challenges posed by certain aspects.
If you require assistance with the preparation of your submission to the CBI, please contact Sean Smith or Laura Wadding.