MiFID II: Potential Prospectus Updates For Funds

Sponsors of UCITS and AIFs are being driven to consider making prospectus changes in light of MiFID II.

While the funds themselves are not subject to the revamp of the EU investment services legislative framework, many will be indirectly affected if they engage EU authorised delegate investment managers or distributors.

The new regime comes into effect on 3 January 2018. 

While prospectus changes are not mandatory, there are a number of aspects that may warrant adjustments. As well as updating IMAs and distribution agreements, we are working with clients on prospectus changes of this nature, including some of the examples considered below: 

1. Product Governance – Disclosing details of each fund's Identified Target Market and also developing clearer, more positive statements in relation to the specific jurisdictions where funds/classes are registered for sale.  For UCITS, it is also a positive statement that the fund and each sub-fund is a non-complex product,