Central Bank of Ireland’s Year-End Approval and Amendment Timeframes for Investment Funds
September 29, 2020
On 28 September 2020, 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”).
It is worth noting that amendments to fund documents that will be required to ensure compliance with Regulation (EU) 2019/2088 on sustainability related disclosures in the financial services sector (the “SFDR”) will not need to be included as part of any pre-year-end submission on the basis the deadline to comply with the SFDR is 10 March 2021.
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 Tuesday 22 December 2020.
| For authorisation / approval / noting on: | Deadline for Receipt: |
| Wednesday 23 December 2020 | 5 p.m. on Tuesday 22 December 2020 |
| Tuesday 29 December 20202 | 3 p.m. on Wednesday 23 December 2020 |
| Monday 4 January 2021 | 5 p.m. on Wednesday 30 December 2020 |
Non-ORION Based Applications (including post-authorisation amendments)3
Normal timeframes will apply until Tuesday 22 December 2020.
| For authorisation / approval / noting on: | Deadline for Receipt: |
| Wednesday 23 / Thursday 24 December 2020 | 3 p.m. on Tuesday 22 December 2020 |
| Tuesday 29 December 2020 | 3 p.m. on Wednesday 23 December 2020 |
| Monday 4 January 2021 | 3 p.m. on Wednesday 30 December 2020 |
Change of Service Provider ("COSP") Filings
| Effective Date of COSP: | Deadline for Receipt: |
| Tuesday 29 December 2020 - Friday 1 January 2021 | 5 p.m. on Tuesday 15 December 2020 |
Individual Questionnaire ("IQ") Filings
Normal timeframes apply until Friday 20 November 2020.
| IQ Application Type: | Deadline for Receipt: |
| IQs relating to QIAIFs | 5 p.m. on Tuesday 1 December 2020 |
| IQs relating to Other Fund Types and Fund Service Providers | 5 p.m. on Friday 20 November 2020 |
Fund / Post-Authorisation Applications (Excluding QIAIFs)
| Application Type: | Deadline for Receipt: |
| Umbrella / Standalone Funds and Non-Fast-Track Sub-Funds4 | 5 p.m. on Friday 16 October 2020 |
| Fast-Track Sub-Funds5 | 5 p.m. on Friday 13 November 2020 |
| Post-Authorisation - Major Items | 5 p.m. on Friday 16 October 2020 |
| Post-Authorisation - All Other Items | 5 p.m. on Friday 13 November 2020 |
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 13 November 2020 |
ICAV Registration / Conversion / Migration Applications
| Application Type: | Deadline for Receipt: |
| ICAV Registration / Conversion / Migration Applications | 5 p.m. on Tuesday 1 December 2020 |
UCITS and RIAIF Authorisations / Approvals / Notings
| For authorisation / approval / noting on: | Deadline for Receipt: |
| Thursday 24 / Tuesday 29 December 20206 | 12 p.m. on Wednesday 23 December 2020 |
| Monday 4 January 20217 | 3 p.m. on Wednesday 30 December 2020 |
Revocations
The Central Bank has noted that all applications must be complete when submitted, and that incomplete applications will be returned and will not be considered for pre-Christmas/pre-year end timeframes.
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. 29 December 2020 is the first day after Christmas that funds may be authorised / approved.
3. Amendments to documents previously filed with the Central Bank and not subject to review.
4. This deadline also applies to self-managed / internally managed investment company / ICAV applications.
5. 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).
6. Tuesday 29 December 2020 is the first day after Christmas that funds may be authorised / approved.
7. Monday 4 January 2021 is the first day of 2021 that UCITS and RIAIF funds may be authorised / approved.
8. Funds seeking to revoke at end of December 2020 must submit a complete revocation application, including payment of the funding levy.
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