Contributing Firms:
The Finance Dublin Funds Monitor Fourth Quarter 2023
In this issue

ELTIF improvements and loan origination changes at top of agenda for 2024


This Month's Roundtable - The Answers

ELTIF 2.0

What potential do you see for the revamped ELTIF? Are you seeing increased interest and activity around ELTIFs from clients/investors as the early 2024 implementation date nears? How well is Ireland positioned to benefit from any increased industry activity in the updated product?


Investor Experience

What are the next major steps to be taken to further develop and streamline the investment journey for investors?


Ireland’s Individual Accountability Framework

With the introduction of an enhanced Individual Accountability Framework (IAF), the Central Bank of Ireland aims to enhance individual accountability in the operation of regulated financial service providers. What effect can the IAF have for Ireland’s reputation as a centre for funds and asset management - e.g. underpinning a more robust international investment funds jurisdiction?


Asset Servicing

A recent survey of alternative fund managers shows the top reasons of those looking to switch service providers included improved service levels, improved quality of data and reporting, better technology and ESG capabilities. In relation to your own business experience, what areas are the current key drivers behind recent business wins?


The role of the custodian

The future role of the custodian has been described as a shift from an asset custodian to a broader data custodian. Please comment on the changing role of the custodian and how you anticipate it will evolve in the coming years.


SFDR

The European Commission has opened a ‘targeted’ consultation on the implementation of the Sustainable Finance Disclosures Regulation (SFDR) with the topics covered including interaction with other sustainable finance legislation; potential changes to the disclosure requirements for financial market participants and the potential establishment of a categorisation system for financial products. Can you comment on this and outline changes/updates that are needed to improve the SFDR framework?


Loan Origination Funds

The proposed update for the Alternative Investment Fund Managers Directive (AIFMD) includes changes regarding Loan Origination Funds that will help to eliminate some of the inconsistencies around the fund type across the EU. In a new departure for AIFMD, for the first time it includes rules at a product level (rather than a fund manager level) - introducing rules around leverage and risk retention for Loan Origination Funds. What are your views on these developments and the potential for the changes to boost the use of Loan Origination Funds?

The Settlement Cycle

ESMA has released a call for evidence on the shortening of the settlement cycle. The EU’s settlement cycle was harmonised in 2014 through the Central Securities Depository Regulation (CSDR) creating an EU-wide T+2 settlement requirement. What would be the challenges/costs to shorten the settlement cycle in the EU and, in your opinion would they outweigh the benefits of a move to T+1 (or T+0)?


Roundtable

The Questions to the Panel

ELTIF 2.0: What potential do you see for the revamped ELTIF? Are you seeing increased interest and activity around ELTIFs from clients/investors as the early 2024 implementation date nears? How well is Ireland positioned to benefit from any increased industry activity in the updated product?

Investor Experience: What are the next major steps to be taken to further develop and streamline the investment journey for investors?

Ireland's Individual Accountability Frameworkt: With the introduction of an enhanced Individual Accountability Framework (IAF), the Central Bank of Ireland aims to enhance individual accountability in the operation of regulated financial service providers. What effect can the IAF have for Ireland's reputation as a centre for funds and asset management - e.g. underpinning a more robust international investment funds jurisdiction.

Asset Servicing: A recent survey of alternative fund managers shows the top reasons of those looking to switch service providers included improved service levels, improved quality of data and reporting, better technology and ESG capabilities. In relation to your own business experience, what areas are the current key drivers behind recent business wins?

The role of the custodian: The future role of the custodian has been described as a shift from an asset custodian to a broader data custodian. Please comment on the changing role of the custodian and how you anticipate it will evolve in the coming years.

SFDR: The European Commission has opened a 'targeted' consultation on the implementation of the Sustainable Finance Disclosures Regulation (SFDR) with the topics covered including interaction with other sustainable finance legislation; potential changes to the disclosure requirements for financial market participants and the potential establishment of a categorisation system for financial products. Can you comment on this and outline changes/updates that are needed to improve the SFDR framework?

Loan Origination Funds: The proposed update for the Alternative Investment Fund Managers Directive (AIFMD) includes changes regarding Loan Origination Funds that will help to eliminate some of the inconsistencies around the fund type across the EU. In a new departure for AIFMD, for the first time it includes rules at a product level (rather than a fund manager level) - introducing rules around leverage and risk retention for Loan Origination Funds. What are you views on these developments and the potential for the changes to boost the use of Loan Origination Funds?

The Settlement Cycle: ESMA has released a call for evidence on the shortening of the settlement cycle. The EU’s settlement cycle was harmonised in 2014 through the Central Securities Depository Regulation (CSDR) creating an EU-wide T+2 settlement requirement. What would be the challenges/costs to shorten the settlement cycle in the EU and, in your opinion would they outweigh the benefits of a move to T+1 (or T+0)?