On the 30th March 2015, the Investor Money Regulations were brought into effect by Statutory Instrument 105 of 2015, with corresponding Guidance Notes published by the Central Bank of Ireland.  These new rules apply to fund service providers, including fund administration firms who operate bank accounts for the collection and payment of money from and to investors in respect of subscriptions and redemptions in funds.  The effective date of the Regulations was 1st July 2016 and have had a significant impact on the daily processes and controls for some fund service providers.  The high level of oversight afforded to client assets generally, coupled with the fact that these are brand new requirements, make it extremely important for firms to understand the requirements and how they can comply. 

The Central Bank of Ireland has sought positive confirmation from each fund service provider in Ireland as to whether they will operate an IMR regime or the alternative Fund Asset Regime.   In the case of the latter, firms will need to reapply to the CBI to have their authorisation amended should they choose to hold Investor Money in the future.  

Deloitte is working with several firms to advise and guide firms through these regulatory requirements and to perform the annual Investor Money Examination. 

1. Client Assets rules 

The Central Bank of Ireland has published a new set of client asset rules for fund services providers. The Investor Money Regulations were brought into effect on 30th March 2015 by Statutory Instrument 105 of 2015. For those in scope, the new rules must be implemented by 1st April 2016. Read more. 

2. Investor Money or Fund Assets

What is the optimum model for your business?

With approximately four months to go before the Investor Money Regulations come into effect, Fund Services Providers are assessing their business and operating models to determine the best fit for their organisation with regard to managing investor money and fund assets. As a result, a number of operating models are emerging across the industry. Read more.