Consultation and Feedback

The Central Bank of Ireland’s (the Central Bank’s) consultation paper (CP145) on macroprudential measures for the Irish property fund sector outlined the Central Bank’s proposal to introduce macroprudential measures to limit leverage (hereafter the “leverage limit”) and liquidity mismatch in Irish-authorised property funds (hereafter termed ‘property funds’).

Stakeholders were invited to provide feedback on the proposals. Twenty responses were received from stakeholders, including alternative investment fund managers (AIFMs), fund investors, alternative investment fund (AIF) service providers, and a range of industry bodies, over a 12-week consultation period from 25 November 2021 to 18 February 2022. The Feedback Received document reproduces the feedback receives from the industry over that period.

The Central Bank would like to thank all stakeholders who took the time to make a submission on CP145. The insights provided by the feedback have fed-into the Central Bank’s deliberations around the calibration and implementation of the proposed measures.

While the feedback was wide-ranging, the majority related to a fixed number of topics. In the case of leverage, these included: 1) the definition of property funds in-scope; 2) the measure of leverage; 3) the use of a single limit; 4) the level of the leverage limit; 5) the approach to counter-cyclicality; 6) the implementation period; and 7) the potential for unintended consequences. In the case of the Guidance on liquidity timeframes (hereafter referred to as the ‘Guidance’), the key issues were 1) the coverage of the Guidance; and 2) the length of the liquidity timeframe.

The final policy proposals for Irish property funds take account of the considerable feedback received from CP145 and further analysis conducted by the Central Bank. Details on the response of the Central Bank are available in the “Feedback Statement & Consultation Paper 145: Macroprudential measures for the property fund sector"