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Central Bank to Make Fund Authorisation Process More Efficient

The Central Bank of Ireland has published a consultation paper (CP67) on the authorisation of regulated firms, funds and intermediaries.  The Central Bank is working towards improving the efficiency and timeliness of response to authorisation applications, without compromising the rigorous assessment of new applicants. The consultation paper sets out proposed new service standards for authorisation activities across a variety of sectors and the proposed dates for their introduction.

The Central Bank aims to deliver a solution for more effective and efficient regulatory processes for the funds sector by Q1 2014.  It has identified a total of 35 process steps out of 59 that will be eliminated in the future funds authorisation process. 

It is anticipated that new authorisation processes will apply to the following key areas:

  • Fitness and probity
  • Return receipts
  • Authorisation of investment funds
  • Post-authorisation activities for funds and investment firms
  • Inward and outward passporting
  • Voluntary revocations
  • Acquiring transactions

The authorisation processes will be improved in a number of ways including:

  • Moving towards electronic applications
  • Offering a secure online portal for application submissions and as a communication tool with the Central Bank
  • Maximising self-certification
  • Issuing of authorisation letters and relevant certificates online
  • Online ability to track application progress
  • Creating a central repository of authorisation and supervisory information
  • Maintaining a complete electronic audit trail of submissions, communications, comments, edits and document versions

The consultation also discusses the Central Bank’s aim to introduce a new authorisation service standard for the authorisation of funds.  The Central Bank is considering two options:

  • The first option is to measure the overall time a fund/sub-fund application is under review within the Central Bank (i.e. a stop-the-clock approach).  The time which an applicant fund/sub-fund takes to address matters raised by the Central Bank during the process is not included in the service standard measure. 
  • The second option is to measure the total time taken to issue a fund/sub-fund authorisation (i.e. beginning-to-end approach).  This option takes account of both the review time of the Central Bank and the time taken by the applicant fund/sub-fund to address issues raised.

It is anticipated that the funds authorisation service standards will apply from 31 March 2014 and the Central Bank will report on performance on a half-yearly basis, with the first half-yearly report to issue for the period Q3-Q4 2014.  Prior to this, the Central Bank will publish a quarterly report for Q2 2014 on an exceptional basis.

The Central Bank has announced its intention to implement the introduction of application fees (CP 61 consultation on impact-based levies and other related matters).  Application fees, as opposed to periodic (annual) levies, will be introduced for demand-driven services.  The application fees will assist in making the processes operationally efficient and organisationally effective and will be payable at the time an application for authorisation is submitted.  It should be noted that fees will not be refunded in the event that an application for authorisation is withdrawn or refused.  The Central Bank will defer the introduction of these fees until 2014 at the earliest.

The closing date for submissions in response to CP67 is Monday 28 October 2013.

Contributed by Michelle McGrath