Central Bank of Ireland Issues Deadlines for Year-End Fund Applications

On 16 September 2019, the Central Bank of Ireland (the “Central Bank”) sent a letter to the Irish funds industry outlining the timeframes for receipt of (i) new fund applications and (ii) post-authorisation amendments that have approval deadlines before Christmas or year-end (the “Year-End Letter”).

The deadlines for receipt of complete applications are set out below:

QIAIF Filings

Applications Submitted Through ORION (the Central Bank’s online reporting system)1

Normal timeframes will apply until Friday 20 December 2019.

For authorisation/Deadline for Receipt:

• Monday 23 December 2019/5 p.m. on Friday 20 December 2019
  Friday 27 December 2019/3 p.m. on Monday 23 December 2019
• Monday 30 December 2019/5 p.m. on Friday 27 December 2019
• Thursday 2 January 2020/5 p.m. on Monday 30 December 2019

Non-ORION Based Applications2

Normal timeframes will apply until Friday 20 December 2019.

For authorisation/Deadline for Receipt:

• Monday 23 December 2019/5 p.m. on Friday 20 December 2019
• Tuesday 24 December 2019/3 p.m. on Friday 20 December 2019
• Friday 27 December 2019/3 p.m. on Monday 23 December 2019
• Thursday 2 January 2020/3 p.m. on Monday 30 December 2019

Change of Service Provider (“COSP”) Filings

Effective Date of COSP/Deadline for Receipt:

• Friday 27 December 2019 – Wednesday 1 January 2020/5 p.m. on Monday 16 December 2019

Individual Questionnaire (“IQ”) Filings

Normal timeframes will apply until Friday 22 November 2019.

IQ Application Type/Deadline for Receipt:

• IQs relating to Other Fund Types and Fund Service Providers/5 p.m. on Friday 22 November 2019
• IQs relating to QIAIFs/5 p.m. on Monday 2 December 2019

Fund / Post-Authorisation Applications (Excluding QIAIFs)

Application Type/Deadline for Receipt:

• Umbrella / Standalone Funds and Non-Fast-Track Sub-Funds/5 p.m. on Friday 11 October 2019
• Fast-Track Sub-Funds3/5 p.m. on Friday 8 November 2019
• Post-Authorisation – Major Items (not defined by the Central Bank)/5 p.m. on Friday 11 October 2019
• Post-Authorisation – All Other Items/5 p.m. on Friday 8 November 2019

Full Review Investment Manager Applications

Application Type/Deadline for Receipt:

• Full Review Investment Manager Applications (i.e., non-EU based applicants)/5 p.m. on Friday 8 November 2019

ICAV Registration / Conversion / Migration Applications

Application Type/Deadline for Receipt:

• ICAV Registration / Conversion / Migration Applications/5 p.m. on Monday 2 December 2019

UCITS and RIAIF Authorisations

Approvals for authorisation/Deadline for Receipt:

• Tuesday 24 December 2019/12 p.m. on Monday 23 December 2019
• Friday 27 December 2019/12 p.m. on Monday 23 December 2019
• Thursday 2 January 2020/3 p.m. on Monday 30 December 2019
  

Revocations

For Revocation/Deadline for Receipt:

• End December 2019/5 p.m. on Friday 6 December 2019

Brexit

With respect to UCITS and retail alternative investment funds (RAIFs), any amendments required to fund documentation arising out of the impending withdrawal of the United Kingdom (the “UK”) from the European Union (“Brexit”) should be submitted to the Central Bank by Monday 30 September 2019.

A QIAIF intending to retain its current UK alternative investment fund manager (“AIFM”), should submit relevant documentation to the Central Bank by Tuesday 1 October 2019. Where a QIAIF is changing its AIFM, the appropriate COSP application should be submitted to the Central Bank by Tuesday 1 October 2019.

If you have any queries, or require any advice in relation to the Year-End Letter, please contact one of the authors. If you are contemplating any pre-Christmas or year-end applications, please get in touch with your usual Dechert contact.

Footnotes

_{1) Applications for Authorisation and Sub-Fund Applications for Approval.
2) Amendments to documents previously filed with the Central Bank and not subject to review.
3) Funds that are reviewed under the ‘fast-track’ process are either: (i) clones of (umbrella or standalone) funds recently approved by the Central Bank; or (ii) non-complex funds (i.e. plain vanilla equity funds which do not use derivatives).}

View full update.