Upcoming CP86 Questionnaire & Inspections

Last week The Central Bank of Ireland’s Director of Asset Management and Investment Banking, Michael Hodson outlined that the Central Bank will be commencing with a questionnaire and onsite inspections to review how firms have implemented the measures introduced under CP86.

As we are all now well aware the objective of CP86 was to introduce initiatives “designed to underpin the achievement of substantive control by Fund Management Companies, acting on behalf of funds, over the activities of their delegates. The guidance applies to “ManCos”, “AIFM’s, self-managed UCITS and internally managed “AIF’s” that are autorised as AIFMs.

CP86 provides guidance on seven key areas:

  • The rationale for board composition.
  • Directors’ time commitments.
  • Organisational effectiveness.
  • Managerial functions.
  • Delegate oversight.
  • Operational issues.
  • Procedural matters

What The Central Bank Said

“We are currently scoping a review of how firms have implemented the measures introduced under CP86.

In line with our normal thematic tools, this body of work will commence with a questionnaire being issued to fund management companies and Self-Managed Investment Companies in the coming weeks with a short turnaround for responses. Once the responses have been analysed, this will then be followed up with desk based reviews and onsite inspections for selected firms.

To be brief, this work will aim to identify standards of industry compliance in order to inform our supervisory approach and ensure that the required effectiveness and systems of governance are in place to protect investors’ best interests.”

ViClarity’s CP86 Compliance Solution

With The Central Bank now turning their attention to CP86 now may be the perfect time to view a demonstration of ViClarity’s automated CP86 compliance tool. The solution is being utilised my numerous fund managers to enable them to automate the process of collecting, collating and reporting on CP86 compliance data.

The ViClarity CP86 solution automatically highlights areas of non-compliance so users can create actions to solve any issues that arise during an audit. The solution has full reporting capabilities which can be shown to management, Board members or regulators when they come knocking.

To see how ViClarity’s CP86 tool can save your organisation 50% of the time on compliance contact neil.osullivan@viclarity.com and book a demo today.