What the changes mean and how they affect you
Client Asset protection is a regulatory priority for the CBI and will remain on the CBI’s supervisory and enforcement agenda due to the serious consequences that deficiencies could have for clients and counterparties as well as reputational damage to the Irish financial market.
Client Asset Requirements are changing and firms have to take steps to ensure they comply with the new requirements. The new requirements bring Fund Service Providers into scope for the first time, others will have to assess how their current framework must be modified.
What are the key changes?
The following are the key changes and additions to the Client Asset Regulations:
- For the first time Fund Service Providers will be subject to “Investor Money Regulations” in respect of client funds held in collection accounts (i.e. bank accounts that are used to receive subscription monies and remit redemption proceeds).
- Firms will be required to appoint an individual as Head of Client Asset Oversight (HCAO) / Head of Investor Money Oversight (HIMO) which will be a Pre-approved Controlled Function, appointed under Part 3 of the Central Bank Reform Act 2010.
- Firms will be required to create, document and maintain a Client Asset Management Plan (CAMP) / Investor Money Management Plan (IMMP) in order to safeguard client assets. The CAMP must be in place by 1 January 2016 for IFs and 1 July 2016 for FSPs.
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