Irish Central Bank reminds funds of year-end filing deadlines

Out-Law News | 06 Oct 2020 | 9:20 am | 4 min. read

The Central Bank of Ireland (CBI) has issued a reminder for fund managers of the annual deadlines for authorisation applications for new funds or sub-funds, as well as a raft of other filings.

In a letter to fund managers (2 page / 273KB PDF), the CBI has set out its deadlines for fund authorisations, as well as post-authorisation amendments, individual questionnaire (IQ) filings, change of service provider filings, investment manager applications, ICAV registration, conversion and migration applications, and fund revocation notifications.

The CBI warned that incomplete applications would be returned and would not be eligible for pre-Christmas or pre-year-end timeframes.

Investment funds expert Ruth Hennessy of Pinsent Masons, the law firm behind Out-Law, said: “Funds and funds service providers should be aware of the Central Bank’s year-end timeframes and should ensure that senior management are cognisant of key dates to ensure that applications can be submitted in a timely manner.”

The deadlines for fund authorisation or post-authorisation applications are as follows:

 Fund/post-authorisation applications Deadline for receipt 
 Funds; non-fast-track sub-funds; self-managed/internally managed investment company/ICAV applications 5pm on 16 October 
 Fast-track sub-funds  5pm on 13 November
 Post-authorisation – major items  5pm on 16 October
 Post-authorisation – all other items  5pm on 13 November

The CBI must receive executed documentation for UCITS or RIAIF authorisations, approvals or notings required on 24 or 29 December by 12pm on 23 December. The first day of 2020 that funds may be authorised or approved is 4 January 2021. Executed documentation must be received by 3pm on 30 December to make the deadline.

Qualifying Irish alternative investment fund (QIAIF) filings may be submitted for processing as normal through ORION until 22 December. Special deadlines apply after this point, as follows:

 For authorisation/approval noting on:  Deadline for receipt
 23 December  5pm on 22 December
 29 December  3pm on 23 December
 4 January  5pm on 30 December

Normal deadlines also apply for submission of QIAIF filings not through ORION until 22 December. After that, the following deadlines apply:

 For authorisation/approval noting on: Deadline for receipt 
 23 and 24 December  3pm on 22 December
 29 December  3pm on 23 December
 4 January  3pm on 30 December

QIAIF change of service provider filings seeking an effective date between 29 December 2020 and 1 January 2021 must be received by the CBI by 5pm on 15 December.

The CBI must receive new investment manager applications by 5pm on 13 November; and ICAV registration, conversion or migration applications by 5pm on 1 December.

Individual questionnaires relating to QIAIFs must be received by the CBI by 5pm on 1 December. Individual questionnaires relating to other fund types and fund service providers must be received by 5pm on 20 November.

Funds seeking to revoke by the end of December 2020 must submit a complete application, including payment of the funding levy, by 5pm on 4 December.