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In October 2020, the Central Bank of Ireland (CBI) announced that all Irish fund management companies (FMC) must be fully compliant with CP86 by the end of Q1 2021.

CP86 builds on guidance on delegate oversight, organisational effectiveness, directors’ time commitments, managerial functions, operational issues and procedural matters.

In December 2016, the CBI addressed substance requirements in their final rules and guidance on the effectiveness of fund management companies – which became effective on 1 July 2018.

Following the implementation of CP86, Self Managed Investment Companies (SMIC) who applied for authorisation from the CBI were required to give greater time commitments from Designated Persons (DP) than before.

As many SMICs rely on external consultants to provide DPs, increased time commitments mean higher costs. For SMICs, the time commitments for DPs apply to the individual DP’s appointed by the SMIC, whereas for a third-party Management Company it applies to the Management Company itself.

It is anticipated that many UCITS and AIF’s may wish to transition to a third-party Management Company like us to assist with the capability to meet the CBI’s substance requirements, rather than encounter any added complexity and cost.

What does CP86 mean for SMICs?

The Central Bank of Ireland’s latest thematic review included updated guidance that all Irish fund management companies (FMC) must appoint a minimum of three full-time employees.

We understand that Self-Managed Investment Companies (SMICs) might feel concerned about the next steps since the CBI's latest CP86 announcements.

Find out how we can help.

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Meet our DPs

Joe O’Donnell - Fund Risk Management

Joe joined LFS in 2014.

He previously worked for Prescient Investment Managers (formerly AIB Investment Managers) where he held various roles including Director of Prescient Fund Management; Member of Executive Committee of Prescient Investment Managers; and Head of Performance Measurement and Investment Risk.

Joe has over 30 years of experience in financial services. He’s a member of the Irish Funds’ Investment Risk Committee and is the Ireland Country Sponsor representative in the Global Investment Performance Standards (GIPS) initiative.

Martin Anderson - Distribution & Capital and Financial Management

Martin joined us as Head of Operations in 2016.

He previously worked at Carne Global Financial Services  as a range of Director and Designated Person roles within Management Companies and Funds. He was also responsible for the Oversight, MLRO and Global Registration teams.

He also worked at RBC Investor Services including oversight of the bank’s global sub-custody network, leading client driven initiatives within Europe and managing the Irish fund administration and custody operation.

Martin qualified as a Chartered Accountant (ACA) in 1991.

Muireann McDevitt - Operational Risk

Muireann recently joined us in 2021. She was previously Head of Fund Operations at Ballybunion Capital, responsible for the oversight of all fund delegates and an approved UCITS Designated Person (PCF-39). 

Muireann has over 18 years of experience in the funds industry working at RBC and Dexia in Dublin and ABN AMRO in Luxembourg.

Paul Phelan - Regulatory Compliance

Paul joined us as Compliance Officer and MLRO in 2012.

He has over 20 years of experience within the funds industry in Ireland. He has a Graduate Diploma in Financial/White Collar Crime Prevention from University College Dublin and is a Fellow of Accounting Technicians Ireland and Licentiate of the Association of Compliance Officers in Ireland.

Patrick McGee - Investment Management

Patrick joined us in 2013 and became a DP in 2020.

He’s held various manager roles including fund accounting and oversight of UCITS, AIFs and Investment Manager Delegates. Before Link Group, Patrick worked at Bank of New York Mellon, HSBC in New Zealand and Credit Suisse in Sydney.

He holds the CIPM designation from CFA Institute and is an active member of the CFA Society of Ireland.

Ireland Management Company

Ireland Management Company website

As your Irish Management Company for either UCITS or AIFM, we can help you meet your obligations under the UCITS and AIFM directives.

Who are we?

We are one of Ireland’s longest-running third-party Management Companies (ManCo), established as an Ireland ManCo in 2006 and authorised and regulated by the Central Bank of Ireland.

With €12.5bn assets under management as of December 2020, we are trusted to tailor our services to fulfil our clients’ needs. We have a unique relationship model along with robust technology to create a seamless interface between our ManCo and the fund accounting and transfer agency services.

Click on our brochure to find out more.


Contact us


Ed Hamilton-Russell

Ed Hamilton-Russell

Head of Business Development (EMEA)

+44 (0)7725 628 137