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ACOI Welcomes our Members to the 4th seminar in the ACOI lunch time CPD seminar series January - June 2012. CPD Reference: 2012-0733 Our Event: Regulatory Updates for The Funds Industry. Chaired: Mr. Ken Sharkey, Chairman of the Funds Working Group, and Compliance Manager, Invesco
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ACOI lunch time CPD seminar series January - June 2012.
CPD Reference: 2012-0733
Our Event:Regulatory Updates for The Funds Industry.
Chaired:Mr. Ken Sharkey, Chairman of the Funds
Working Group, and Compliance Manager, Invesco
Speakers:Mr. Kevin O’Doherty, Regulator Affairs Consultant,
Compliance Ireland and Mr. Shay Lydon, Partner, Matheson Ormsby
3 April 2012
Topic 5 – IFIA Corporate Governance Code for CIS and ManCos
Topic 6 – Central Bank of Ireland Fit & Proper Regime
Requirement to be Fit & Proper:
Persons who are subject to the Fit & Proper Standards must:
Topic 7 – Central Bank of Ireland PRISM system
Prism is the Central Bank’s key new supervisory assessment tool:
Prism is designed to allow Central Bank to:
Assets under management
Breakdown of Impact categories
High (Including ultra high) – circa 20 firms
Medium high – circa 70 firms
Medium low – circa 450 firms
Low – circa 10,300 firms
Central Bank will engage with firms at a level that corresponds to their impact category. Engagement will consist of a variety of reviews, assessments and meetings.
High impact firms will receive an inspection visit every quarter with each visit having a different focus.
Medium-high impact firms will have full risk assessments conducted very 2 to 4 years.
10% of medium-low impact firms will be subject to proportionate full risk assessment visits each year
Low impact firms will be regulated using a combination of reactive and thematic techniques. Technology will analyse financial returns. Supervisors will receive automatic alerts when a low-impact firm fails key financial health checks.
Consumer focused low impact firms will be subject to thematic visits to ensure that they are treating customers fairly.
Summary inspections will be conducted occasionally.
Supervisors not only will analyse and identify risks, they should focus on ensuring appropriate and achievable mitigating actions are taken to address any risks deemed unacceptable.
Any risk category that is probability rated as medium high or high must be mitigated.
A Risk Mitigation Programme(RMP) will be opened. One or more outcome focused actions to reduce the risk will be constructed by the supervisor. A deadline will be given.
Examples of an RMP could be to raise more capital, cease a particular activity or strengthen the control framework. Occasionally it may include telling a firm that the staff running a particular business line or support function lack the requisite skills and to address this.
RMP will be focused on risks which if left unmitigated could ultimately threaten the financial future of the firm or lead to a material mistreatment of consumers.