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ARTICLE · 04 JULY 2014

Mind Your KIIDs!

Dillon Eustace
Dillon Eustace
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Dillon Eustace

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The Financial Conduct Authority published its final notice to Invesco Asset Management Limited and Invesco Fund Managers Limited.

IrelandFinance and Banking
Dillon Eustace
Dillon Eustace
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On 24 April 2014, the Financial Conduct Authority (the 'FCA') published its final notice to Invesco Asset Management Limited and Invesco Fund Managers Limited (together, 'Invesco') imposing a fine of STG £18,643,000 (reduced from over STG £26,632,900 due to a discount because Invesco agreed to settle at an early stage) for certain internal control failures and for failing to ensure that certain Invesco UCITS' key investor information documents ("KIID") complied with the applicable legislation. In particular, the FCA found that the relevant KIIDs did not comprehensively detail the downside risk associated with the use of derivatives.

This note briefly summarises the KIID requirements under Directive 2008/65/EC ("UCITS IV"), the reasons given by the FCA for the fine imposed on Invesco and some thoughts as to how UCITS and their management companies may avoid a similar penalty.

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