On 30th June 2020, the Irish Funds responded to the Consultation Paper – Implementing technical standards for cross border distribution.

Specific Questions:

Do you agree that the information to be published should concern not only requirements applicable specifically to the marketing of investment funds, but should also encompass a general statement relating to the potential application of other bodies of law applicable.

Yes, the association agree with this approach and the requirement of National Competent Authorities (“NCA’s”) to publish and maintain, on their websites, up to date and complete information on the applicable national laws, regulations, etc. for AIFs and UCITS, as a minimum.

Do you agree with the proposed approach regarding the format of the publications to be made by NCAs on their websites in respect of marketing requirements for UCITS and AIFs? If not, please provide alternative suggestions.

Yes, the association agrees with the proposed approach and propose that there is also a requirement imposed to ensure the information is date stamped and a requirement imposed to ensure the information is refreshed, reviewed and updated annually at a minimum.