The Central Bank has updated its UCITS Q&A to note its expectations in relation to the filing of Key Investor Information Documents ("KIIDs") for UCITS which are implementing the European Securities and Markets Authority ("ESMA") Performance Fee Guidelines ("Guidelines") with effect from 31 December 2021.
The Central Bank has confirmed that a UCITS with a financial year end of 31 December 2021 that is implementing changes to its performance fee methodology to comply with the Guidelines may elect to make either: (a) two KIID filings, one to reflect the changes arising from the implementation of the Guidelines and one to meet the KIID filing obligations under the UCITS Directive; or (b) a single filing to meet the KIID filing obligations by 22 February 2022.
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