The Institute has received a number of inquiries from members regarding the possible requirement to be regulated by the Central Bank as well as by CARB for certain activities undertaken by the regulated firm, specifically under the Central Bank’s Debt Management Firm regime.
In common with the CCAB-I bodies it is the Institute’s understanding that where such services are provided by a firm which is already regulated by an accountancy body, it meets the exemption criteria of ‘….an accountant who provides debt management services only in an incidental manner and is subject to regulation by a professional body’.
Our interpretation of Section 28 of the Central Bank Act 1997 (as amended) is that Chartered Accountants Ireland members providing such services through a regulated firm which provides other services falls within the category of ‘excepted person’.
For many of our regulated practices the provision of Debt Management Services will be incidental to the myriad of services they provide to clients. Therefore, pending clarification from the Central Bank, it is our view separate authorisation from the Central Bank is unnecessary.
The Institute and CARB have written to the Central Bank outlining our views and await a formal response. We will update members as further developments arise.