On 22 August 2012 the Central Bank indicated that it would waive its disclosure requirement relating to connected party transactions for current reporting periods.
The background to this matter is that in recent months, the Central Bank had been engaging with industry concerning the disclosure of “connected party” transactions as provided for in UCITS Notice 14 and non-UCITS Notice 2. (This is separate and distinct from the “related party” disclosure requirements under FRS8 which focuses on fee payments and dealings in units with respect to parties which exercise control over the reporting entity (fund)). The disclosure requirement concerns transactions carried out with a fund by its promoter, manager, trustee, investment adviser and/or associated or group companies. A report of the transaction entered during the reporting period must be provided in the annual and half yearly reports. The report must include a list of all transactions by type, the name of the related company and, where relevant, fees paid to that party in connection with the transaction. The Central Bank had outlined that it anticipated that the report would include information in relation to fee payments, dealings in units, forex transactions, deposits and OTC transactions. The IFIA had made submissions to the Central Bank in relation to the onerous nature of, and volume of disclosures necessitated by, the disclosure requirement, following which the Central Bank has agreed to waive the disclosure requirement for the current period pending a review of these submissions.
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