The Central Bank of Ireland (CBI) held its Markets in Crypto-Assets Regulation (MiCAR) – Industry Briefing today, with a very well attended session.
Addressed by Derville Rowland, Deputy Governor, Consumer and Investor Protection, she said that CBI’s commitment is to be clear, transparent, predictable, and open.
The important pre-application phase is now open, and drawing on the VASP registration experience, Mary-Elizabeth McMunn, Director of Banking, Payments and Credit Union Supervision, emphasised the importance of the pre-registration meetings facility.
She said that previously only 50% of firms took up the option for pre-registration meetings.
Our experience, she said, was that those firms that took up pre-registration meetings were the firms that found their progress easier through the VASP registration process, and that is an interesting reflection for the MiCAR registration process.
McMunn said, if coming from a fintech background, it is important to have the right regulatory expertise and support to engage with a regulatory process like this.
There is no fast pass through from a VASP registration to a CASP MiCAR registration, there are significant differences, said McMunn.
Firms were reminded that for anyone who has gone through the VASP registration, their primary contact is their supervisor, for others who have not, the Innovation Hub is their contact point.
The pre-application phase is very important and provides the opportunity to discuss business models with the CBI and for CBI to continue to outline its supervisory expectations, under the headings:
- Governance and accountability
- Conflict of interest
- Protection of client assets
- Ownership
- Business model and financial resilience
- AML/CTF
- Operational Resilience
- Crisis Management
- Conduct and transparency
These would be conducted under the engagement principles of:
- Transparency
- Supervisability
- Preparedness
- Customer Focus
UPDATE 23/07/2024:
The Central Bank of Ireland has updated its MiCAR webpage with the following:
- Speech by Derville Rowland
- The Central Bank’s MiCAR Authorisation and Supervisory expectations as presented by Mary-Elizabeth McMunn
These additional resources provide a wider context and some specifics on MiCAR authorisation processes and timelines.
