Central Bank publishes the Forty-Fourth Edition of the Central Bank AIFMD Q&A Document

On 20^th December, the Central Bank issued the 44^th Edition of the Central Bank AIFMD Q&A, which includes three new Q&A’s, ID 1151, 1152 and 1153.

ID 1151 sets out the Central Bank’s expectations in respect of an arrangement involving a non-discretionary investment advisor which provides services to a QIAIF. The Q&A affirms the Central Bank’s expectation that the investment advisor is performing a role that is advisory in nature and the AIFM must be able to evidence this upon request from the Central Bank.

ID 1152 sets out the Central Bank’s expectations that multi-manager Retail Investor AIFs (“RIAIFs”) will comply with ESMA’s Q&A of July 2021 on performance fees in multi-manager AIFs. It confirms that existing multi-manager RIAIFs must bring their performance fee methodologies into compliance by 1 January 2023. 

ID 1153 addresses the circumstances of establishment of a new multi-manager RIAIF utilising a performance fee and notes that those wishing to establish a new multi-manager RIAIF with a performance fee must do so in compliance with ESMAs Q&A of July 2021 on performance fees in multi-manager AIFs.

See all previous versions of the AIFMD Q&A.