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knowledge 15 August 2019 |

Brexit: Do You Need to Update Your Funds Documents?

All updates to funds documents (eg prospectus, supplements, agreements etc) resulting from Brexit must be submitted to the Central Bank of Ireland (“CBI”) by 30 September 2019, according to a recent letter circulated by the CBI (the “Letter”).

In the Letter, the CBI reminds all boards that they are responsible for ensuring that each investment fund is adequately prepared for the impact of Brexit. According to the CBI, the board should determine if any amendment to a fund’s documentation is necessitated, such as:

  • amendments to the list of regulated markets to remove references to the United Kingdom as a European market; or
  • policy updates as required to clarify the geographical focus of a UCITS or Retail AIF.

The Letter also states that “Such updates must be submitted to the Central Bank by 30 September 2019 in order to be in place for 31 October 2019”.

The CBI previously issued a letter to the Funds Industry on 17 November 2017, highlighting the need for UCITS Management Companies, Alternative Investment Fund Managers and the boards of self-managed UCITS and AIFs to ensure that funds under their remit were adequately prepared for the impact of Brexit, including making any required updates to fund documents.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.