ALFI UCITS IV implementation project – KID Q&A Document
ALFI UCITS IV implementation project – KID Q&A Document
ALFI UCITS IV implementation project – KID Q&A Document
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of funds but one or more third party distributor (such as a fund platform) is not yet able to accept <strong>KID</strong>s, wouldit be possible for these funds to offer both SPs and <strong>KID</strong>s? The SP would be distributed by the platform that isunable to accept <strong>KID</strong>s.A. Art 118(2) of the <strong>UCITS</strong> Directive says “that <strong>UCITS</strong> [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 <strong>KID</strong> has been published the SP is obsolete and should not be used.CESR/10-1319, Box 3, Para 1 says, “A management company shall always provide the same type of document(whether simplified prospectus or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 <strong>UCITS</strong>’ 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 <strong>KID</strong> hasbeen issued, the management company and all distributors in all EU member states should stop using the SP for that<strong>UCITS</strong>.<strong>ALFI</strong> <strong>KID</strong> Q&A, Issue 1314, 11 April25 September 2012 Page 60