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Central Bank Online Reporting System Update

The Central Bank of Ireland’s (the “Central Bank”) Online Reporting System (“ONR System”) is now fully operational and Regulatory Returns (the “Returns”) for Irish authorised collective investment schemes (“CIS”) are now to be filed through it.

This follows the issuance in May 2012 of Consultation Paper 59, which outlined proposed changes to the regulatory reporting requirements of CIS.

Subsequently, the Central Bank issued a letter to the Board of Directors of CIS in relation to the appointment of a System Administrator in respect of each CIS. CIS System Administrators will be responsible for ensuring that the Returns are filed electronically with the Central Bank. Where delegate System Administrators are appointed, with responsibility for filing a specific Return, the CIS System Administrator must ensure that they have been allocated access to the ONR System and are aware of their responsibilities.

The Central Bank opened its delegation process for CIS System Administrators for a 2 week period up until 29 March 2013. During this period, CIS System Administrators delegated selected Returns to either the Fund Administrators or Fund Legal Advisors.  Third party users may also be set up at any stage.

The following Returns allocated to the CIS Board of Directors appeared on the ONR System from 9 April 2013:

1.    Annual and interim financial statements
2.    Annual Financial Derivative Instrument (“FDI”) Report – UCITS only
3.    Annual Sub-Fund Profile Return
4.    Annual update of Key Investor Information Document (“KIID”) – UCITS only
5.    CIS reporting of material breaches, material errors, significant matters and suspensions (“Regulatory Report”)

The Technical Committee of the Irish Funds Industry Association has now issued guidelines for Fund Administrators with regard to the ONR System.

The Guidelines address the role of the CIS and the delegated System Administrator and also includes recommendations for the delegation of the Returns.