Chapter 9: Risk Management

Head of Investor Money Oversight

  1. In general, the Central Bank expects a director to be appointed as Head of Investor Money Oversight (HIMO). If this is not the case, the HIMO should be a senior manager within the fund service provider with direct access to the board in respect of that function.
  2. The board of the fund service provider (the board) is ultimately responsible for safeguarding investor money, the requirement to have a HIMO role does not detract from this.
  3. The board should ensure that the individual undertaking the role of HIMO can demonstrate that he / she is free from any conflicts of interest in this area and document this in the Investor Money Management Plan (IMMP). In this regard, the HIMO should be sufficiently removed from the performance of day-to-day operational functions relating to the administration of investor money. The Board should document in the IMMP the rationale for the nomination and appointment of the HIMO, including the criteria used by the fund service provider in making the appointment.
  4. It is the board’s responsibility to ensure that the HIMO role is allocated to an individual with adequate authority, training, resources and expertise. The board should note that the individual proposed for the HIMO role is subject to pre-approval by the Central Bank and is required to comply with the Fitness and Probity Standards on an ongoing basis thereafter.
  5. The fund service provider should arrange for appropriate cover to ensure the HIMO duties are addressed where the HIMO is on leave.
  6. The fund service provider should document clear and distinct reporting obligations for the HIMO in the IMMP. Where the HIMO holds other roles within the fund service provider and has more than one reporting line, this should be clearly called out.
  7. Depending on the nature, scale and complexity the fund service provider, the HIMO may require staff to support delivery of their responsibilities. The reporting lines, roles and responsibilities of those individuals should be clearly documented.
  8. A periodic re-assessment of HIMO resourcing requirements should be undertaken and documented by the fund service provider. The responsibilities of the HIMO should be tailored to the business model of the fund service provider.
  9. The HIMO should provide on-going training to employees of the fund service provider, including board members, in order to increase knowledge and awareness of investor money obligations, and to promote a culture of engagement and challenge.
  10. The HIMO should undertake regular reviews of the IMMP to ensure that its contents are accurate and up to date.

Issued: 4 July 2023

Last revision: 4 July 2023