Ireland:
Getting Operationally Compliant With The ESMA Share Class Opinion
21 July 2017
Maples Group
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By 30 July 2017 UCITS will need to comply with the terms of the
ESMA Share Class Opinion.
Helpfully, the Central Bank have indicated in their Q&A that
prospectus updates can be carried out "at the time of the next
update of your prospectus".
But away from the prospectus disclosure/transparency aspects,
UCITS should also be reviewing their operational processes to
ensure their share class currency hedging techniques comply with
the provisions in the Opinion (and the Central Bank's
corresponding Guidance, as updated on 28 June 2017).
In the case of UCITS, the
responsible person should also ensure that under-hedged positions
do not fall short of 95% of the portion of the NAV of the share
class which is to be hedged and keep any under-hedged position
under review to ensure it is not carried forward from month to
month.
https://www.centralbank.ie/regulation/industry-market-sectors/funds/ucits/guidance/ucits-and-aif-share-class-hedging
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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