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.

 

Irish Regulatory Matters

The CBI is currently consulting on new cross-industry guidance on outsourcing and operational resilience.

AIFMD

The EU's Cross-Border Distribution of Funds Directive and Regulation came into force on 2 August 2021. Review of the AIFMD and the related Level 2 Regulation is currently ongoing. A European Commission proposal is expected in November/December 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 a consultation paper on draft new outsourcing guidelines.

IFR/D

A new bespoke EU prudential regime. Effective from 26 June 2021. New investment policy disclosure template published by the EBA. ESMA and EBA seeking feedback on SREP Guidelines and RTS on Pillar 2 add-ons through 18 February 2022. Final sound remuneration and internal governance under IFD published by EBA and ESMA with a 30 April 2022 effective date.

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 have publish its updated IFD remuneration guidelines. 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.