There is now just a week to go until the expiry on Friday 30 September of the FCA’s transitional provision for UCITS V prospectus updating.
The UCITS V Directive was implemented by the FCA in its UCITS V Directive Instrument 2016 and contained a requirement to include disclosures in UCITS funds’ prospectuses as from 18 March 2016 around the following:
- the depositary’s duties and conflicts of interest;
- the depositary delegations of safekeeping; and
- remuneration disclosures.
The FCA’s transitional provision allowed any prospectus issued before 18 March to delay compliance until 30 September. AFMs have made use of this additional time to fit with other prospectus updates or to prepare their underlying revised remuneration policies. Even if work on these remuneration policies may still be ongoing, the prospectuses will have to be updated before 1 October.
NURS prospectuses must also be updated in relation to the depositary’s duties, conflicts of interest and delegation, but the FCA extended the deadline for this to 31 March 2017.