New Registration and Reporting Requirements for section 110 Companies

Section 110 companies that are not Financial Vehicle Corporations (“FVCs”) are now obliged to register with the Central Bank of Ireland (“Central Bank”) and provide it with quarterly balance sheet and annual profit and loss data.

FVCs have been required to report statistical data to the Central Bank since 2009, under a European Central Bank Regulation. In July 2015 the Central Bank’s quarterly bulletin included an article identifying potential financial stability issues arising from the activities of special purpose vehicles (“SPVs”) and announcing the Central Bank’s intention to extend quarterly reporting requirements to SPVs.

The new reporting regime applies to non-FVC section 110 companies that are incorporated in Ireland and the information to be provided under the regime is similar to that currently provided by FVCs to the Central Bank. In October 2015 the Central Bank published notes on the compilation of the Special Purpose Vehicles Return, which are available available here.

The Central Bank is considering whether to extend the reporting requirement to non-Irish incorporated non-FVC section 110 companies.

The first quarterly returns are due on 20 November 2015.