Client Asset and Investor Money Regulations

This paper explains the role of system-based solutions in complying with Ireland's Client Asset and Investor Money Regulations.

The Central Bank of Ireland's Client Asset and Investor Money Regulations are a blend of broad principles and detailed guidance put in place to ensure a firm is exerting adequate governance over client money and asset protection.

These regulations are implemented through two statutory instruments:

  • SI 104 for Investment Companies - Since 1st October 2015
  • SI 105 for Fund Service Providers (FSPs) - Since 1st April 2015

Regulated firms are required to appoint a senior executive. These roles are designated as PCF45 Head of Client Asset Oversight (HCAO) and PCF46 Head of Investor Money Oversight (HIMO) for investment managers and FSPs respectively.

The Need for System-Based Solutions

Put simply, the PCF45/ PCF46 needs to ensure that they have adequate system-based solutions in place. Our paper - Client Asset and Investor Money Regulations: How to Comply with Ireland's Toughest Protection Rules – will take you through the key principles and considerations of the regulations, including:

  • The Overall Approach of the Regulation
  • The Role of the PCF45/ PCF46
  • Segregation Requirements
  • Designation and Registration Rules
  • The Need for Daily Reconciliation and Calculation
  • The "Client Asset Key Information Document" (CAKID)
  • Client Asset/Investor Money Examinations


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