#CP86

Implementation

Objectives:

Short-term:  

Ensure you are fully ready from an operational and governance perspective. 

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Complete Clarity across leadership team regarding roles, regulatory responsibilities and escalation procedures. 

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Long-Term: 

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Regulator Intelligent is good for business. 

#CP86Solution

IMPLEMENTATION

Success Indicators:

1. Directors, Designated Persons and Senior Leadership team have confidence that your firm is organised and operating in compliance with the Central Bank’s expectations, regulatory obligations and industry best practices

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2. Regulatory obligations under AIFMD, UCITS and CP86 are allocated to delegates for performance and Designated Persons for oversight

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3. Frequency for reporting on regulatory obligations is set, taking into account the level of activity in the investment fund and escalation parameters are agreed

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4.  Your firm and the Organisational Effectiveness Director have clear understanding of how the Organisational Effectiveness Role will be carried out and how it will add value

#CP86Solution

IMPLEMENTATION

Value:

• Regulator Intelligent is more than just avoiding regulatory fines. It ensures you are improving your relationship with the Regulator

• Get the operational and compliance framework for your Firms right from the outset avoiding the need for costly repairs and reengineering at a later date

• Strengthen negotiating position with delegates by understanding the regulatory source of the requirements you are asking them to perform

• Support front line staff and reduce staff turnover by providing training and a framework that helps them understand their roles and what is required of them

#CP86Solution

Phase 1

Build the Designated Persons Framework

To allocate regulatory responsibilities to individual Designated Persons for oversight and to specific individual delegates for performance; to set the frequency of reporting by delegates to Designated Persons and by Designated Persons to board; and to set escalation parameters.

#CP86Solution

PHASE 2

Policies and

Procedures

To put in place a comprehensive set of policies and procedures that ensures your Firm's regulatory requirements are complied with and that allocates responsibility for performance to a specific delegate(s) and oversight to a specific Designated Person

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PHASE 3

Organisational

Effectiveness Role

To design and implement the Organisational Effectiveness Role for Amundi in a way that complies with the requirements of CP86, that meets the Central Bank’s expectations and that adds value to the governance and operation of your Firm

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Phase 4

Directors

To ensure that the directors are clear about the Central Bank’s expectations of them, to put in place letters of appointment that map fully to CP86 and to establish a robust process for the approval of new funds by the board

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PHASE 5

Board 

Governance

To assist the Company Secretarial Team in understanding how to support the your Firm's board and in developing board agendas and an annual activity calendar

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PHASE 6

Wrap-Up

To ensure that the Senior Leadership team are aware of the work undertaken and outcomes resulting from the CP86 Implementation Programme

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