Central Bank publishes updated Guidance on Client Asset Requirements and Investor Money Requirements to coincide with the revised Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Investment Firm) Regulations 2023

The revised Client Asset Requirements (CAR) set out in Part 6 of the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Investment Firms) Regulations 2023 (S.I. No. 10 of 2023) (the Regulations) became applicable to investment firms on 1 July 2023. The revised CAR will become applicable to credit institutions from 1 January 2024. The protection of client assets is a key priority for the Central Bank and the enhancements to the CAR aim to ensure that client assets held by investment firms and credit institutions, authorised by the Central Bank, remain appropriately safeguarded.

On 4 July 2023, the Central Bank published updated Guidance on the CAR, and on the Investor Money Requirements (IMR), as contained in Part 7 of Regulations. The Guidance is intended to be read in conjunction with the CAR and IMR and its primary purpose is to assist investment firms, credit institutions subject to the CAR and fund service providers subject to the IMR in complying with the Regulations.

The revised CAR Guidance broadly reflects the draft CAR Guidance that has been available on the Central Bank website since June 2022.

The revised IMR Guidance replaces the version previously available on the Central Bank website and provides additional guidance for fund service providers, particularly with respect to how they structure and document key information in their Investor Money Management Plans.