Q. The Central Bank's Guidance on 'Umbrella funds - cash accounts holding subscript ion, redemption and dividend monies' sets out 'that at all times the amounts within the umbrella cash account can be attributed to the individual sub-funds in order to comply with constitutional documents'.
Are there circumstances where this may not be possible?
A. Yes. In accordance with paragraph 1(iii) under the heading "Treatment of subscription, redemption and dividend monies in umbrella cash accounts" in the Central Bank's guidance on 'Umbrella funds - cash accounts holding subscription, redemption and dividend monies' it may not be possible to attribute monies in the umbrella cash account for a period of time where subscription money is received with insufficient documentation to identify the owner. This could occur where -
i. A subscription application has been received and subscription monies have been received into the umbrella cash account but the subscription monies cannot be matched to t
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