The Central Bank of Ireland (the “central bankâ€) Sent a communication to the Irish fund industry on 1 December 2021, outlining the timelines for receipt of: (i) authorizations / approvals and QIAIF notes; (ii) ICAV registrations and revocation requests; and (iii) UCITS and RIAIF approvals / approvals during the Christmas period (the “End of year communication“).
It should be noted that the changes to the substantive documents that will be necessary to ensure compliance with Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (the taxonomy regulation) (which s ‘apply from 1 January 2022) must be made no later than 14 December 2021 as part of the accelerated process announced by the Central Bank in November 2021.
The deadlines for receipt of complete applications are indicated below.
QIAIF deposits1
Normal deadlines will apply until Wednesday, December 22, 2021.
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For Authorization / Approval / Noting on: |
Deadline for receipt: |
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Thursday 23 December 2021 |
3 p.m. Wednesday, December 22, 2021 |
|
Friday, December 24, 2021 |
3 p.m. Wednesday, December 22, 2021 |
|
Wednesday, December 29, 20212 |
3 p.m. Thursday, December 23, 2021 |
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Thursday, December 30, 2021 |
3 p.m. Wednesday, December 29, 2021 |
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Friday, December 31, 2021 |
3 p.m. Thursday, December 30, 2021 |
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Tuesday, January 4, 2022 |
5 p.m. Friday December 31, 2021 |
Change of Service Provider (“COSPâ€) Deposits (QIAIF only)
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COSP effective date: |
Deadline for receipt: |
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from Monday December 27, 2021 to Friday December 31, 2021 |
5 p.m. Monday December 13, 2021 |
ICAV Registration / Conversion / Migration Applications
|
Effective date: |
Deadline for receipt: |
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Thursday 23 December 2021 – Friday 31 December 2021 |
5 p.m. Friday December 10, 2021 |
UCITS and RIAIF approvals
Note that the following is for final repositories (i.e. once free of comments) and not initial requests.
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For Authorization / Approval / Noting on: |
Deadline for receipt: |
|
Friday, December 24, 20213 |
12 noon on Thursday 23 December 2021 |
|
Wednesday, December 29, 2021 |
12 noon on Thursday 23 December 2021 |
|
Thursday, December 30, 2021 |
12 noon on Thursday 23 December 2021 |
|
Friday, December 31, 2021 |
12 noon on Thursday 23 December 2021 |
|
Tuesday, January 4, 20224 |
5 p.m. Friday December 31, 2021 |
Revocations
|
For revocation: |
Deadline for receipt: |
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End of December 2021 |
5 p.m. Monday December 13, 20215 |
The Central Bank did not provide any details regarding the deadlines for: (i) Filing of individual questionnaires (IQ); or (ii) Full review of investment manager applications (ie applicants based outside the EU, including UK). We understand that this is on the basis that the Central Bank expects these deposits to be already made if it waits for authorization before the end of the year.
The Central Bank noted that all applications must be complete when submitted, and incomplete applications will be returned and will not be considered for periods before Christmas / before the end of the year.
Footnotes
1) Approval requests and requests for approval of the compartments.
2) Wednesday, December 29, 2021 is the first day after Christmas that funds can be authorized / approved.
3) Wednesday, December 29, 2021 is the first day after Christmas on which UCITS and RIAF funds can be authorized / approved.
4) Tuesday January 4, 2022 is the first day in 2022 when UCITS and RIAIF funds can be authorized / approved.
5) For Funds wishing to revoke at the end of December 2021, a complete revocation request, including payment of the fundraising drawdown, must be received before Monday, December 13, 2021.