Update to the Central Bank of Ireland’s pre-submission process for QIAIFs

Regulatory Update

25 September 2022

The Central Bank of Ireland (CBI) removes requirement for pre-submission process for Loan Origination QIAIFs (Lo-QIAIFs), Real Estate Funds not investing in Irish property and Life Settlement Funds.

In a development which will be welcomed by many in the funds industry in Ireland, the Central Bank of Ireland (CBI) has published new guidance regarding its pre-submission requirements for certain types of qualifying investor alternative investment funds (“QIAIFs”).

Revised requirements

The updated guidance means there will no longer be a requirement to do a pre-submission for Lo-QIAIFs and Life Settlement Funds. The pre-submission requirement will remain for property funds investing in Irish funds and for any Crypto funds (with the exception of funds allocating no more than 10% of NAV to bitcoin futures traded on the Chicago Mercantile Exchange).

While the Central Bank will continue to conduct post-authorisation checks, the removal of the pre-submission requirement for Lo-QIAIFs and Life Settlement Funds is a welcome development as firms will now have more certainty on timing with the 24 hour approval process for QIAIFs applying. Coupled with the launch of Ireland’s revised Investment Limited Partnership (ILP) regime in 2021 Ireland is now a more attractive location to domicile private funds.

For Funds investing in Irish Property and crypto-assets the following documentation will be required in making a pre-submission: Prospectus & Supplement; Model portfolio; Leverage; Liquidity and target market assessment. For any existing funds, shareholder approval will be required to gain exposure to crypto-assets. Further developments are likely in this area.

How Carne can help

Carne has extensive experience in supporting Lo-QIAIF funds, working with some of the world’s leading credit managers. Carne has also led the way among third-party management companies in supporting ILPs. Carne acted as AIFM to the first private equity fund launched under the new ILP regime and worked with 75% of the new ILP launches using third-party management companies in 2021.

Carne also supports private funds domiciled in Luxembourg, the Channel Islands and the UK through locally domiciled management companies in those locations and in Cayman through an expert team of local resident directors.

 

For further information, please contact your Carne relationship manager or Patrick O’Brien.

Ireland

Patrick O’Brien
Head of Business Development
+353 1 489 2481
patrick.obrien@carnegroup.com

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