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Markets Update: UCITS & AIFMD Q&A, IMR and Umbrella Cash Account Updates

24 March 2016

Please note the Central Bank of Ireland (CBI) have today published a Markets Update on their website, which can be found here.

The update covers several aspects in relation to Investor Money Regulations (IMR) and the treatment of Umbrella Cash Accounts for subscriptions and redemptions, including:

  • The publication of the amending IMR Statutory Instrument (SI no 87 of 2016) which formally moves the start date of IMR to 1 July 2016.
  • A revised guidance on Umbrella Cash Accounts holding subscription, redemption and dividend monies, which can be found here, and which provides for these accounts to be applied to cleared fund models.
  • A revised UCITS Q&A and revised AIFMD Q&A, which both provide information on the conditions where the above umbrella cash accounts may have unattributed money for up to 5 working days on an exceptional basis. They also provide that only monies payable to investors or to sub-funds should flow through these accounts.

Finally, a question has been added with information around Securities Financing Transaction Regulation disclosures.

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