Ireland: 2022 Horizon Scanning For Fund Managers

Fund managers may have been relieved to see out 2021, a year in which all funds had to be classified as Article 6, Article 8 or Article 9 funds under the Sustainable Finance Disclosure Regulation ("SFDR") in advance of the 10 March deadline, prospectus amendments to reflect the Taxonomy Regulation Level 1 requirements had to be filed by year end, action plans to comply with the Central Bank of Ireland ("Central Bank") Dear Chair letter of 20 October 2020 on Fund Management Company Effectiveness ("CP86") had to be put in place, the Central Bank's Guidance on Performance Fees was published and the Central Bank engaged with managers in relation to the common supervisory action on costs and fees.

Legislative and regulatory change will continue apace in 2022. At a global level, the industry has doubled in size since the 2008 financial crisis, bringing significant benefits to the real economy, while also attracting increasing regulatory focus arising from concerns relating to financial stability. Leverage and liquidity are likely to continue to feature on the regulatory agenda, with the Central Bank's consultation on property funds representing one step towards increased macro-prudential regulation. Financial stability concerns also led to the publication of the Central Bank's Guidance on Operational Resilience and Guidance on Outsourcing in late 2021. Compliance with these guidelines will be a significant project for all regulated financial service providers in 2022, together with completing the mandatory disclosure templates for pre-contractual, periodic and principal adverse impact disclosures under the SFDR and the Taxonomy Regulation, engaging with the Central Bank on its planned thematic inspection in relation to SFDR / Taxonomy Regulation compliance, the application of the PRIIPs KID requirements to UCITS and compliance with ESMA and the Central Bank's guidance on performance fees.

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