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CP86 Dear Chair Letter – What’s Your Plan?

AUTHORs: Tara Doyle Services: Asset Management and Investment Funds DATE: 26/02/2021

Following on from the Central Bank of Ireland's (“Central Bank”) Dear Chair Letter issued on 20 October 2020, which set out the Central Bank’s findings following its thematic review of the implementation of its Guidance for Fund Management Companies (known as CP86), fund management companies (“FMCs”) are now working on the action plans required to be discussed and approved by boards by the end of March 2021.

The Central Bank letter called on all FMCs (including self-managed investment companies or SMICs), whether or not the FMC has received a risk mitigation programme from the Central Bank, to critically assess their day to day operational, resourcing and governance arrangements against all relevant rules and guidance, taking into account the findings of the Central Bank’s thematic review.  For an overview of the findings in the Central Bank’s letter, see our earlier update here.

To assist FMCs in assessing their compliance with the Central Bank’s rules and guidance and in considering their future options, we have launched our CP86 Dear Chair Letter – What’s Your Plan? webcast series, which includes the following presentations:


What Next for SMICs?

Donal O’Byrne discusses the future feasibility of SMICs and how SMICs can comply with the Central Bank’s expectations.

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Establishing a Management Company

Senior Associate Eunan Hession discusses the option of establishing a proprietary management company.

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Gap Analysis for Existing Management Company

Senior Associate Orlaith Finan examines the Central Bank’s findings set out in the Dear Chair letter and outlines the steps management companies may need to take to ensure compliance.

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Our CP86 Dear Chair Letter: What’s Your Plan? webcast series is our second webcast series of 2021.  Our first series – Are you SFDR Ready? – addresses key areas covered under the EU Sustainable Finance Disclosure Regulation (which applies from 10 March 2021) including: the new ESG-related disclosure requirements applicable to all funds; requirements applicable to Light Green Funds and Dark Green Funds; the principal adverse impact statement; and sustainability risk policies and remuneration policies.  The five webcasts may be viewed in full here.