As mentioned above, the CBI covers a number of other matters in the Update that are not discussed in detail in this update. These items include:
Pillar 3 Disclosures
The CBI expects MiFID investment firms that are subject to the Capital Requirements Regulation and Capital Requirements Directive IV to advise of any delay, the reasons for such delay and, to the extent possible, the estimated publication date of their Pillar 3 reports, if they are delayed.
Client Asset and Investor Money Requirements
The Central Bank will allow certain flexibility for investment firms and fund service providers, in respect of deadlines for the submission of assurance reports in respect of investment firms and fund service providers’ arrangements for the safeguarding of client assets or investor money for submissions falling due from April to July 2020 inclusive, where it is not possible to comply with the applicable deadlines as a result of COVID-19 related issues.
Additional Data Requests
To examine the effects of COVID-19 on the financial sector, the CBI has indicated that it will require additional targeted information to be submitted by investment firms (such as the requested made relating to liquidity) during this period and that it will expect firms to reply to such requests in an expedient manner.
Risk Mitigation Programmes (RMPs) for Investment Firms and Fund Service Providers
The CBI states that it expects investment firms to be in a position to meet the existing RMP implementation dates and to engage with the Central Bank where they have difficulties in relation to meeting specific RMP submission dates.
Updates to Central Bank Regulatory Policy Frameworks
The CBI will delay updates to any regulatory policy frameworks relating to the funds industry, specifically its feedback statement in relation to Treatment, Correction and Redress of Errors in Financial Statements.
The CBI confirms that it will apply measures outlined in recent announcements by ESMA as described in the Update. The blanket application of the ESMA measures by the Central Bank should provide some reassurance to industry participants that any further measures announced by ESMA will also be implemented by the CBI.