Irish Manager Members Steering Group

Overview:

The Irish Manager Members Steering Group (IMMSG) is a forum for peer-to-peer discussion.  The group also provides policy direction for the work of AIMA’s Government and Regulatory Affairs team with respect to asset management regulation, private credit regulation, markets regulation and tax affairs in relation to Irish local laws and regulations and European laws and regulations as implemented in Ireland.

The IMMSG is composed of representatives of AIMA member firms authorised as AIFMs, UCITS management companies or MiFID investment firms by the Central Bank of Ireland. IMMSG meetings are convened on a quarterly basis.

 

AIFMD

The European Commission has published a proposal to review the AIFMD. The legislative proposal covers delegation, liquidity risk management, loan funds, investors disclosures, depositaries and regulatory reporting matters. The EU's Cross-Border Distribution of Funds Directive and Regulation came into force on 2 August 2021.

UCITS

The European Commission has proposed targeted amendments to the UCITS Directive on liquidity management tools, delegation and reporting. The proposals are now being scrutinised by the European Parliament and Council. Separately, the EU and the UK have both confirmed extension of the UCITS exemption under PRIIPs to 31 December 2022 in the EU and 31 December 2026 in the UK.

Responsible Investment

AIMA's resources for implementing responsible investment (also known as 'ESG') and interpreting the relevant regulation. Notable research papers and relevant events are also linked.

Outsourcing

The increasing use of outsourcing by regulated entities is of growing importance to a number of supervisory authorities. ESMA guidelines on cloud outsourcing came into force on 31 July 2021. The CBI has issued new outsourcing guidelines.

IFR/D

A new bespoke EU prudential regime. Effective from 26 June 2021.

MiFID

From ESMA proposals to modify the scope of the transaction reporting requirement to FCA proposals to remove RTS 27 and RTS 28 best execution reports, reviews of the MiFID II/MiFIR regulatory framework at EU and UK level are currently underway. See here for an overview of developments and AIMA’s regulatory and policy engagement.

EU Remuneration

IFR/IFD remuneration requirements effective as of 26 June 2021. EBA and ESMA have publish their updated IFD and MiFID II remuneration guidelines, respectively. Notable other EU remuneration requirements under AIFMD and the UCITS Directive are also linked.

Tax (EU)

AIMA’s current European tax advocacy encompasses key topics such as hybrids and other mismatches, financial transactions tax and EU non-cooperative tax jurisdictions.