Ireland – CM EAM

2024, Cross-border, Update

Country Manual Independent Portfolio Manager/Advisor (EAM)

Ireland – Update 2024

BRP SA - Ireland-Dublin-Trinity-College-CM-EAM
BRP SA – Ireland-Dublin-Trinity-College-CM-EAM

BRP has updated its Country Manual Independent Portfolio Manager/Advisor (EAM) for Ireland out of company’s country of establishment (Def, RS & BT)

  SOURCE OF CHANGESANSWERS
  Law/Regulation  No
  New Position of the Authorities  No
  Evolution of Expert’s interpretation  Yes

Regulatory Summary and Behaviour Template

Material changes

There have been no material changes to Irish law or regulation which would have a significant effect on the answers in the Template since the last update. There have been a small number of interpretive changes in particular:

  • For actively presenting an EAM in general terms to a qualified prospect, the answer is now Grey zone/YES to emphasise that any such presentation should only be in relation to investment services – banking services cannot be touched upon during such a presentation.
  • For account opening on a reverse solicitation basis by remote means it is now emphasised that this should only be for a limited number of prospects.

Non-material changes

Further references to Irish MiFID II regulations have been added in particular Regulation 51 on reverse solicitation. Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the EAM Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “IRELAND” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in colour). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Best regards,

Geneva, June 18th, 2024

Go back