ESMA clarified in December 2019 that Money Market Fund managers must send their first quarterly reports to national regulators by the end of Q1 2020. The EU Money Market Fund Regulation (MMFR) was implemented in July 2018. Article 37 of the MMFR requires that a fund manager report certain information for each money market fund that it manages to the Central Bank of Ireland. This information should be reported on at least a quarterly basis for money market funds with assets of 100 million or more. For money market funds with assets under management of less than 100 million reporting is on at least an annual basis.
The Central Bank of Ireland advised Irish Funds that the filing of the first reporting under the MMFR is deferred until July 2020. The filing of the first reports for Q1 2020 is due in April. However, more time is required in order to prepare the reporting infrastructure.
The quarterly reporting under the MMFR for Q2 2020 will also be due in July 2020. This means that both Q1 and Q2 2020 reporting under the MMFR will be due in July 2020. At that time, the Central Bank will validate the returns to ensure that they comply with requirements. Any returns that fail a validation will be returned and will be required to be resubmitted once the validation issues are resolved.
Irish Funds will continue to engage with the CBI on the implementation of the MMFR reporting requirements.
