ALFI UCITS IV implementation project – KID Q&A Document

of funds but one or more third party distributor (such as a fund platform) is not yet able to accept KIDs, wouldit be possible for these funds to offer both SPs and KIDs? The SP would be distributed by the platform that isunable to accept KIDs.A. Art 118(2) of the UCITS Directive says “that UCITS [should] replace their simplified prospectuses … with keyinvestor information.” CESR/10-1319 uses the same language. In our view the reasonable interpretation of the text isthat once the KID has been published the SP is obsolete and should not be used.CESR/10-1319, Box 3, Para 1 says, “A management company shall always provide the same type of document(whether simplified prospectus or key investor information) to investors in the UCITS’ home state and in every hoststate in which it is notified”. See also the explanatory text at Para 9 on the same page. In our view, once the KID hasbeen issued, the management company and all distributors in all EU member states should stop using the SP for thatUCITS.ALFI KID Q&A, Issue 1314, 11 April25 September 2012 Page 60