Central Bank of Ireland’s Year-End Approval and Amendment Timeframes for Investment Funds

 
November 14, 2023

On 10 November 2023, the Central Bank of Ireland (the “Central Bank”) sent a communication to the Irish funds industry outlining the timeframes for receipt of:

  1. QIAIF authorisations / approvals / notings and change of service provider (“COSP”) filings;
  2. ICAV registration and revocation applications; and
  3. UCITS and RIAIF authorisations / approvals during the Christmas period

(the “Year End Communication”).

Deadlines for receipt of complete applications are set out below:

QIAIF Filings1

For authorisation / approval / noting on: Deadline for Receipt:

Thursday 21 December 2023

3 p.m. on Wednesday 20 December 2023

Friday 22 December 2023

3 p.m. on Wednesday 20 December 2023

Wednesday 27 December 20232

3 p.m. on Thursday 21 December 2023

Thursday 28 December 2023

3 p.m. on Wednesday 27 December 2023

Friday 29 December 2023

3 p.m. on Thursday 28 December 2023

Tuesday 2 January 2024

5 p.m. on Friday 29 December 2023

COSP Filings (QIAIFs only)

Effective Date of COSP: Deadline for Receipt:

Wednesday 27 December 2023 – Monday 1 January 2024

5 p.m. on Friday 15 December 2023

ICAV Registration / Conversion / Migration Applications

Effective Date: Deadline for Receipt:

Friday 22 December 2023 – Sunday 31 December 2023

5 p.m. on Friday 8 December 2023

UCITS and RIAIF Authorisations / Approvals / Noting

Note the following relates to final filings (i.e., once clear of comment) and not initial applications.

For authorisation / approval / noting on: Deadline for Receipt:

Friday 22 December 20233

5 p.m. on Wednesday 20 December 2023

Wednesday 27 December 2023

5 p.m. on Wednesday 20 December 2023

Thursday 28 December 2023

5 p.m. on Wednesday 20 December 2023

Friday 29 December 2023

5 p.m. on Wednesday 20 December 2023

Tuesday 2 January 20244

5 p.m. on Thursday 28 December 2023

Note the following relates to initial applications (i.e., Draft 1 applications / applications that are not reasonably expected to be submitted for approval by Wednesday 20 December 2023).

Initial applications intending to be submitted for authorisation / approval by: Deadline for Receipt:

Wednesday 20 December 2023

5 p.m. on Friday 15 December 2023 (“Initial Applications Deadline”).

Where applications (initial and later drafts) are received after the Initial Applications Deadline, these applications will take a received date of 2 January 2024.

Fund Service Provider (“FSP”) Authorisations

Acquiring Transaction Notification Forms (“ATNFs”)

If FSPs plan on submitting an ATNF to the Central Bank on any day between Wednesday 20 December 2023 and Wednesday 3 January 2024, the Central Bank should be notified of this intention to submit by Tuesday 19 December 2023 via email to mancofspauthorisations@centralbank.ie.

Revocations

For Revocation: Deadline for Receipt:

End December 2023

5 p.m. on Friday 15 December 20235

The Central Bank has not provided any detail in relation to timelines for: (i) Individual Questionnaire (IQ) Filings; or (ii) Full Review Investment Manager Applications (i.e., non-EU, including UK, based applicants).

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


Footnotes

  1. Applications for Authorisation and Sub-Fund Applications for Approval.
  2. Wednesday 27 December 2023 is the first day after Christmas that funds may be authorised / approved.
  3. Friday 29 December 2023 is the first day after Christmas that UCITS and RIAIF funds may be authorised / approved.
  4. Tuesday 2 January 2024 is the first day of 2024 that UCITS and RIAIF funds may be authorised / approved.
  5. For funds seeking to revoke at end of December 2023, a complete revocation application, including payment of the funding levy must be submitted by 5 p.m. on Friday 15 December 2023.

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