The Central Bank of Ireland has published the fifth edition of its UCITS Q&A which now includes a new question (ID 1013) on fund redomiciliations.
The Central Bank has clarified that an investment fund which re-domiciles to Ireland as a UCITS is permitted to disclose its past performance in its Key Investor Information Document (KIID) provided that:
- The UCITS investment policy, strategy and portfolio composition have not been substantially altered as a consequence of the transfer to the UCITS regime.
- There is no change to the entities involved in the investment management of the UCITS.
- It is satisfied that the past performance data is accurate.
- Appropriate disclosure will be included with the past performance in the KIID stating that the data relates to a period when the investment fund was domiciled outside Ireland and was not authorised as a UCITS.
This is a positive development for AIFs who may wish to disclose past performance as a non-UCITS to investors.