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Asset and portfolio management
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FinTechs belonging to this category offer asset and portfolio management services via an internet platform or software programs and usually manage and dispose of the assets of their customers long or short term according to their specifications without actually holding the property or the possession of those assets. FinTechs, which provide information about and access to overnight or time deposit accounts at national and foreign banks and which execute the transactions to these accounts, also belong to this category. Some FinTechs however only act on request of the customer.

Aside from that some FinTechs offer software or internet solutions enabling users to manage and plan their personal finances on their own by providing graphics, overviews and compilations of their financial data and sometimes indicating financial risks or opportunities, but without actually managing the assets.

Introduction

Attitude of the country towards modern asset and portfolio management services

The Irish market has seen a significant influx of asset management firms setting up a presence in Ireland to ensure continuity of access to the EU.

As well as being subject to the requirements that derive from Irish and European legislation, Alternative Investment Fund Managers (AIFM) are also subject to various other regulatory requirements based on the nature of their activities and the associated risks.

Legal affairs

Obligations and requirements to provide asset and portfolio management, or ancillary services described above

AIFMs are authorised under the European Communities (Alternative Investment FundManagers Directive) Regulations 2013 (the AIFMD Regulations) which transpose the EU Alternative Investment Fund Managers Directive (AIFMD) into Irish law.

For AIFM authorisation in Ireland, the Central bank requires:

    a) the applicant is a body corporate with registered and head office in Ireland;
    b) the applicant meets the specific regulatory capital requirements (as outlined below);
    c) its shareholders, directors and managers satisfy all fitness and probity requirements;
    d) its directors and managers have sufficient experience in the type of AIF being managed;
    e) the group structure does not prevent effective supervision by the Central Bank;
    f) satisfaction that the AIFM will be able to meet the conditions of the AIFMD Regulations and AIFMD Level 2 (provides for capital and authorisation requirements).

Capital requirements:

    a) Self-managed AIFMs are required to have an initial capital of €300,000. An external AIFM is required to have initial capital of at least €125,000 in place plus 0.02% of the value of the portfolios of the fund it manages in excess of €250 million, subject to a cap of €10 million.
    b) There is an additional requirement for external AIFMs to have in place insurance for an amount equal to 0.90% of the Assets under Management (AUM) or alternatively to hold additional capital equivalent to 0.01% of the AUM.

The normal timeframe for getting authorised as an AIFM is 4 to 6 months from the submission of a complete application to the Central Bank.

Additional comments regarding the legal situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

N/A.

Economic conditions

Market size for asset and portfolio management services and biggest companies in this business area

There are 194 authorised and registered AIFM’s in Ireland at present.

According to the Irish Funds Industry Association, Ireland is a leader for both AIF and UCITS products. Total assets under administration are approx. €4.3 trillion. Irish domiciled funds amount to over €2.2 tri

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