In its June 2015 CP86 feedback statement, the Central Bank stated that it would proceed to streamline the existing managerial functions to be performed by UCITS management companies and AIFMs in the manner proposed in CP86, through the restructuring of the overall number of these to six functions, from nine and fifteen respectively. The six managerial functions will be investment management; fund risk management; operational risk management; distribution; regulatory compliance; and capital and financial management.
The organisational requirements for AIFMs in the AIF Rulebook have now been updated to reflect the six streamlined managerial functions. While the same person may perform more than one managerial function, a new rule provides that the same person must not perform managerial functions in relation to risk management and investment management.
The Central Bank will require existing fund management companies and self-managed investment companies to update their business plans / programmes of activity to reflect the revised managerial functions by 30 June 2016.
By Matheson
