Ireland and Luxembourg have both made announcements designed to give comfort to their funds that use UK based portfolio managers:
- The Deputy Governor of the Bank of Ireland said in a speech that it was making good progress in its preparations for a hard Brexit. These will include ensuring that consumers can continue to be serviced by UK and Gibraltar firms who have sold them products (although the firms will not be able to write new policies or business). He also said he is confident that appropriate MOUs (including bilateral ones) will be in place to ensure a sustainable link between the EU and UK and said it was reasonable for firms to plan on the basis that these would be in place by 29 March, so that firms that delegate portfolio management to the UK can “have sufficient confidence that this will continue to be allowed post 29 March”;
- the Luxembourg CSSF said that it would endeavour for the required co-operation between the FCA and CSSF to be in place on 29 March to meet the conditions under the AIFMD and UCITS directive to permit delegation of investment/portfolio management and/or risk management to UK undertakings to be possible without any disruption in the event of a hard Brexit.