Central Bank of Ireland Requires UCITS Managers to Review Liquidity Risk Management Frameworks

The European Securities and Markets Authority (ESMA) recently concluded an E.U.‑wide review of the liquidity risk management (LRM) practices of Undertakings for the Collective Investment in Transferable Securities (UCITS) fund managers. The review was conducted by the relevant regulator of each member state. Although ESMA found generally sound LRM processes, it identified a number of areas where some managers have room for improvement. Following the publication of ESMA’s findings, the Central Bank of Ireland (Central Bank) issued its own letter to the industry, flagging the specific issues it identified in its review of Irish UCITS managers and directing all supervised Irish UCITS managers to conduct an in-depth review of their LRM policies and procedures. This article analyzes both ESMA’s public statement and the Central Bank’s letter to industry, with commentary from Donnacha O'Connor, partner at Dillon Eustace, and Declan O’Sullivan, partner at Dechert. For more on liquidity risk, see “FSOC Report Focuses on Liquidity, Leverage and Other Risks Facing Hedge Fund and Asset Managers” (Apr. 28, 2016).

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