The AIFM Regulations 2013 and Central Bank of Ireland’s Fund Management Company (FMC) Guidance places significant obligations on Irish authorised fund management companies to have in place numerous written policies and procedures. In some instances, an AIFM will place reliance on its delegates to ensure that the AIFM is complying with its obligations; in other instances, it does not rely on delegates. Where an AIFM chooses to rely on its delegates, the Central Bank has set out in the FMC Guidance its expectations concerning the steps which the AIFM should take to ensure that this is appropriate. In particular, an AIFM must have a written policy or procedure even where it is placing reliance on a delegate.
How to use this template
This template lists the policies and procedures which an AIFM is required to have under the AIFM Regulations 2013 and the FMC Guidance. It also sets out a framework for putting these policies and procedures in place including the key provisions which must be covered in accordance with regulatory requirements.
Please note that this template does not include policies and procedures required by other regulatory requirements (e.g. fitness & probity, anti-money laundering, etc.).
Please also note that this template sets out a framework for an AIFM’s policies and procedures - it does not contain detailed text for these policies and procedures.