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UCITS IV: Time for changeThe Asset Management Industry’s views on theKey Information Document

Asset Management

June 2010

2 PricewaterhouseCoopers in association with EFAMAUCITS IV: Time for change The Asset Management Industry’s views on the Key Information Document

Foreword by PwC and EFAMAIn the course of summer 2010, Europe’s asset managers will learn thefinal form of the most extensive regulatory upheaval they have faced inmany years.

Whilst at different stages in thelegislative process, UCITS IV and theAlternative Investment Fund Managersdirectives will be implemented bythe EU.

Within UCITS IV, one of the fewcompulsory measures is the KeyInformation Document (KID), which onthe face of it appears straightforward.Yet the KID has far more wide-reachingimplications than asset managerscurrently realise.

Our survey canvassed a broad crosssection of managers, and it clearlyshows that many have not yetunderstood the KID’s significance.Most strikingly, 58% of respondentshad not considered the costimplications of changes to theirsystems and controls to implementthe KID.

In fact, large asset managers may needto produce thousands of KIDs eachyear. The KID will, in all likelihood, haveto be prepared at the share-class level,meaning the number of documents tobe produced and disseminated will

increase significantly compared to thesimplified prospectus. Furthermore, theKID contains new requirements whichthe fund managers will have to complywith. As a result, managers need tostart urgently planning to adapt theiroperations and systems accordingly.

Beyond this, the KID may also changethe way in which funds are perceived.Retail investors may start todifferentiate between products on thebasis of the new risk indicators, leavingsome managers with gaps in theirproduct ranges. Managers would ideallywant to promote funds covering theentire risk spectrum.

UCITS IV was conceived to introducea level playing field for fund distributionacross Europe, yet with tax andregulatory differences remaining withincountries its measures can not havefull impact. Through this surveyand our respective activities,PricewaterhouseCoopers1 (PwC) andEFAMA are working hard to help assetmanagers to anticipate how they canbest prepare.

We will be carrying out two moresurveys to solicit asset managers’views and to judge their levels ofpreparedness. The first of these willreview the Management CompanyPassport, and will be publishedin September.

Peter de ProftDirector GeneralEFAMA

Thierry BlondeauRegulatory & UCITS IV Project LeaderPricewaterhouseCoopers (Luxembourg)

Sally CosgroveUK Funds & UCITS IV LeaderPricewaterhouseCoopers (UK)

Ken OwensAsset Management Regulatory& UCITS IV LeaderPricewaterhouseCoopers (Ireland)


Contents01 Executive summary 4

02 Introduction 6

03 Will the KID provide comparable and consistent information? 8

04 A level playing field for funds? 10

05 A better understanding of a product’s risks and rewards? 12

06 Does a synthetic risk indicator work? 14

07 Will civil liability be applicable to the KID disclosures? 16

08 What are the implications of implementing the KID? 18

09 Perceived challenges of the KID requirements 20

Contacts 21

1 “PricewaterhouseCoopers” and “PwC” refer to the network of member firms of PricewaterhouseCoopersInternational Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL orany other member firm.

014 PricewaterhouseCoopers in association with EFAMA

UCITS IV: Time for change The Asset Management Industry’s views on the Key Information Document

Executive summaryThis is the first in a series of surveys that PwC, in conjunction withEFAMA, will be conducting in relation to the implementation of theUCITS IV Directive.

The objective of these surveys is toascertain the intentions of the AssetManagement industry and thechallenges it faces with regards to:

• The new UCITS requirementsrelated to the Management CompanyPassport;

• The new Key Information Documentthat will replace the existingSimplified Prospectus; and

• The restructuring toolkit that allowsasset managers to pool theirassets by merging their Europeaninvestment funds on a Europeanbasis and/or adopting master-feederstructures.

This document analyses the responsesthat were received in relation to theKey Information Document (KID).The findings demonstrate that theindustry has not yet fully assessed theimplications relating to the productionof the KID and many requirementssurrounding its production are deemedchallenging.

We set out below the most criticalthemes, issues and implications theAsset Management industry faces inlight of the requirement to producethe KID.

1. The KID is deemed to be a step inthe right direction in providinginvestors with consistent andcomparable information to makesound investment decisions;although 60% of the respondents areconcerned the level of detail may notbe sufficient.

2. The Asset Management industry isnot confident that the KID will helpcreate a level playing field for fundswithin Europe through providingcomparable and consistentinvestment information.

3. 54% of respondents believe that theKID will provide the investor with abetter understanding of a product’srisks and rewards.

4. 76% of the respondents do not thinkthat the use of a synthetic riskindicator works for all types ofUCITS.

5. 50% of the respondents believethat civil liability will be applicable tothe KID disclosures, a further 25%being unsure.

6. 58% of respondents have notconsidered the cost implicationsof changes to their systems andcontrols to implement the KID.

7. Investment management companieshave identified many KIDrequirements that they believe arechallenging.




IntroductionOne of the changes under UCITS IV will be the replacement of theSimplified Prospectus for UCITS with the Key Information Document(KID). The KID is intended to be a concise and focused presentationof information for prospective investors of UCITS funds.

The UCITS IV Directive states that:“Key investor information shall includeappropriate information about theessential characteristics.....to beprovided to investors so that they arereasonably able to understand thenature and the risks of the investmentproduct.....and, consequently, to takeinvestment decisions on an informedbasis.”

Recommendations from the Committeeof European Securities Regulators(CESR) on the Level 2 measurescovered a number of areas of the KID,including:

• The description of the strategy andobjectives of the fund should becombined in a single section of theKID and written in plain language;

• The risk and reward disclosureshould be presented via a syntheticrisk and reward indicator (SRRI)accompanied by a narrativeexplanation;

• Past performance information shouldbe presented in a bar chart, usingpercentages and covering a period ofup to 10 years;

• KIDs should be compulsorilypublished on two pages of A4-sizedpaper (i.e. the front and back of onsheet of paper); and

• KIDs should be updated at leastonce a year, within 35 business daysafter 31 December each year.

PwC and EFAMA asked key players inthe industry, ranging from fund housesto asset servicing groups, to participatein this survey. The findings demonstratethat the industry has not yet fullyassessed the implications relating tothe production of the KID and manyrules are deemed challenging.

The following pages provide analysis ofthe results of the survey representingthe Asset Management industry’s view.




The KID is deemed to be a step in the right directionin providing investors with consistent andcomparable information to make sound investmentdecisions; although 60% of the respondents areconcerned the level of detail may not be sufficient.

One of the aims of the KID is to createa level playing field for providing fundinformation throughout Europe in orderto help investors make informedinvestment decisions. The majority ofsurvey respondents believe that the KIDgoes some way to achieving theseaims. Indeed, over 70% of respondentsbelieve the KID will help investors toassess, understand and compareproducts.

The KID versus the SimplifiedProspectus

Respondents were asked how theywould rate the KID compared to theSimplified Prospectus. Over 80% ofsurvey respondents believe that the KIDwill be either much better or better.

Amongst those who believe the KIDwill be an improvement in comparisonto the Simplified Prospectus, therewas a view that the KID wouldbe a “useful tool for comparativepurposes”. However, a notuncommonly expressed view wasthat whilst the Simplified Prospectus“was an initiative that worked well intheory…in practice, after regulatorsand lawyers expanded it, it becamebloated and excessively complicated.”

Will the KID provide sufficientdetail for sound investmentdecisions?

Whilst it is the case that the majorityof the survey respondents believe theKID will help investors make soundinvestment decisions, there were also anumber of concerns over whether thetwo pages of the KID will be sufficientto give all the information they need tomake sound investment decisions: 60%of respondents believe that the KID willnot achieve this. The major concernsinclude:

• The limited content and length maypresent a challenge in disclosing allof the necessary information.

• The KID will be able to offer a goodoverview of products, but to fullyunderstand their strategy it is likely toneed further marketing support.

• With increasingly complex UCITS IIIproducts, it will be a challenge toexplain them in such brevity.

• The level of detail required willdepend on the sophistication of thepotential investor.

The views highlighted abovedemonstrate that there are concernsaround whether or not the KID canprovide investors with all the relevantdetails necessary to make soundinvestment decisions. A further concernexists around the quality and therelevance of the information disclosedin the KID. There is a mixed view overwhether the KID delivers greatertransparency over fund managementcharges and products risks andrewards – this is further analysed onpage 13.

Concluding thoughts

Even though the KID is more likely tobe read by potential investors thanthe Simplified Prospectus, it is thoughtthat “only by referring to the fullprospectus, will the investor have allthe information on a fund”.

Additionally, a view given by severalrespondents indicated that a moremodern approach to providinginvestment information and enhancingcomparability should be taken.“A central internet comparison sitewhere investors could go to comparea number of funds for free with thecosts being borne either by theinvestment managers or the fundsthemselves” was at the heart of thissolution.


Assessproducts

Understandproducts

Compareproducts

Do you think the KID will help investors:

n Yes n No n Don’t know

76%

19%

5% 3% 2%

27% 22%

76%70%



The Asset Management industry is not confident thatthe KID will help create a level playing field for fundswithin Europe through providing comparable andconsistent investment information.

The UCITS IV directive aims to provideinvestors with consistent information onUCITS funds across Europe via theintroduction of the KID – this, amongother factors, could help create a levelplaying field across Europe.

Will the KID look the samein every European MemberState?

Just less than 50% of the respondentsbelieve that the KID will look the same,no matter what the European country oforigin. Even though many respondentsare “hopeful”, or feel that “it would behelpful if the KID did look the same”,they are not confident that this aimwill be achieved. A view held is thatthere are stylistic differences betweendifferent countries and that even thoughthere are guidelines on the mainpoints that need to be included,fund managers will use discretion in“how these are laid out and how thenumbers are derived”.

A level playing field inEurope?

When asked whether the consistencyof information provided by the KID willhelp create a level playing field forfunds within Europe, the views ofrespondents were mixed. Only 45% ofthe respondents thought it was likely orvery likely, that this would be the case,and 30% felt it was quite or veryunlikely.

There is uncertainty in the marketplaceover the effectiveness of the KID. This ishighlighted through the widespreadresults, and the varying commentsmade by the respondents.

Although the KID will be a “force forconsistency”, non comparableinformation across funds in Europe isnot the sole factor creating the unlevelplaying field across Europe with regardsto UCITS funds. Rather it is the“harmonisation of marketing andtaxation rules across funds”, as wellas a consistent set of regulations andstandard applications across theMember States that would help createand promote this level playing field.In addition, it is believed that access isthe key to levelling the playing field.More coordination between regulatorswould unfortunately not solve all theissues around marketing and taxation.

Concluding thoughts

There appears a level of uncertaintywithin the asset management industryas to whether the aims of the KID willbe achieved in providing identicalinformation on funds across Europeanmember states. We believe that due tothe prescriptive nature of the disclosurerequirements for the KID, and the factthat these requirements need to be metwithin 2 pages of text and diagramsthat it is likely that the KID will be afairly standard document, no matter itscountry of origin. Nevertheless, astandardised document to comparefunds can only go so far in creating alevel playing field across UCITS fundsin Europe.



Will the KID look the same in every Europeanmember state?

Verylikely

Quitelikely

Neither/nor

Quiteunlikely

Veryunlikely

Don’tknow

6%3%

39%

22%19%

11%

How likely is it that the KID will help create a levelplaying field in Europe?

48%

22%

30%



54% of respondents believe that the KID willprovide the investor with a better understandingof a product’s risks and rewards.

A major objective of the proposedKID is to provide greater transparencyto investors over the managementcharges and risk and reward featuresof a fund. To that end, the Directiveprescribes that the followinginformation on a fund is disclosed inthe KID:

• its strategy and objectives;

• its risks and rewards expressedthrough a synthetic risk and rewardindicator (SRRI) and narrativeexplanations;

• its charges, including entranceand exit, ongoing and contingentcharges; and

• performance data for the past10 years

However, the results of the surveysuggest that there is mixed opinion overwhether the KID will be able to deliveron its objective.

Risks and reward

The SRRI will be the key metric todetermine and disclose a UCITS fundsrisk profile. Whilst 54% of surveyrespondents agree that the KID willprovide the investor with a betterunderstanding of a product’s risks andrewards, still a large proportion of therespondents were still either unsure ordisagreed with this.

Those expressing concern seem tobase this on the view that “risks andrewards of funds can only be fullyunderstood by sophisticatedinvestors” and that “it depends on aninvestor’s knowledge of investmentrisk”. Many expressed a view that theSRRI, the key measure of risk, mayactually be misleading and not easilyunderstood by retail investors.

Management charges

Only 41% of the respondents believethat the KID will deliver greatertransparency around managementcharges.

This stems largely from the beliefthat the information to be disclosed inthe KID will be the same as thatcurrently available, as “figures will notdiffer from what is currently in the[simplified] prospectus”. Respondentsdo not seem to think that “the detaildiffers that much from what iscurrently shown”.

Concluding thoughts

There is a view that there will be littledifference between the managementcharge disclosures in the KID ascompared to the simplified prospectus.Investors seeking further information onmanagement fee charges can readilyaccess this information currentlythrough various sources, such as factsheets, financial statements and theSimplified Prospectus. However, theKID will assist in ensuring consistentdisclosures enabling comparisonsbetween different funds.

Concerns over the SRRI have been wellpublicised to date. We discuss thisfurther in the next section.


The KID will provide the investor with a betterunderstanding of a product’s risks and rewards

Verylikely

Quitelikely

Neither/nor

Quiteunlikely

Veryunlikely

Don’tknow

How likely is it that the KID will provide greatertransparency over management charges?

3% 3%

38%

24%

13%19%

Stronglyagree

Agree Neither/nor

Disagree Stronglydisagree

Don’tknow

3% 3%

51%

19% 21%

3%



76% of the respondents do not think that theuse of a synthetic risk indicator works for all typesof UCITS.

The Committee of European SecuritiesRegulators (CESR) guidance on theKID asks for a UCITS’s risks andrewards to be expressed through asynthetic risk and rewards indicatorsranging from 1-7. The risk figure isto be calculated on the fund’s historicvolatility using five years of data.The risk rating needs to be reviewedover the life cycle of the fund and theKID needs to be updated every timethe rating changes.

This methodology of determining riskapplies equally to traditional relativereturn funds, absolute or total returnfunds, and even structured products.

Appropriateness of asynthetic risk indicator

76% of the respondents do not thinkthat the use of a synthetic risk indicatorworks for all types of UCITS.

The concerns included the following:

• There are “a multiplicity of risks ininvesting and one measure cannotpossibly catch them all”.

• There is a risk that determining anddisclosing the synthetic risk indicatormay become “an exercise in tickinga box to meet a regulatoryrequirement”.

Accurate expression offunds’ risk through a syntheticrisk rating?

Nearly a third of the respondents feel“not very confident” or “not confidentat all” that they could provide anaccurate risk rating for a fund’s riskthrough a numerical rating system of 1-7.

However, accuracy is not the onlyconcern. Respondents are concernedabout comparability; i.e. will thecompetition use the same methodologyto determine the risk factor. “As we willnot be privy to how other investmenthouses are rating their funds, we willnot be able to ensure that we areconsistent with them”. There is alsoa concern that there will be significantbunching of funds into a few riskcategories and initial research wouldseem to indicate that this is likely to bethe case. Some respondents believe atthe time of the survey that SRRI is justone indicator of risk and that it willshow “relative rather than absoluterisk in practice”. Finally, the SRRI maynot link to performance: “A level 1 fundcould still perform worse than a level 7fund depending on which particularmarket conditions were prevalent”.

However, on the flip side, there arethose that feel somewhat confident(46%) or very confident (8%) abouttheir ability to determine an accuraterisk rating through the proposedrating system.

Concluding thoughts

The synthetic risk indicator seems tobe the most discussed requirementof the KID. The concern is that not allinvestors will understand how the riskindicator was determined. Currentthinking also indicates concern that themajority of funds will end up within twoto three of the risk categories – makingcomparisons difficult.

Additionally, recent history hasdemonstrated how quickly risks canchange and how a changing economicenvironment can change the perceptionof risk. The risk rating may give falsecomfort to investors, as the ratingcannot be assessed in isolation butneeds to be reviewed in the context of

the environment, the investor’s riskappetite and their investment portfolio.However, are all investors sufficientlysophisticated to make their ownpersonal assessment?


Do you think the use of a synthetic risk indicatorworks for all types of UCITS?

How confident are you that you can accuratelyexpress your products’ risks and rewards througha rating from 1–7?

Veryconfident

Somewhatconfident

Neither/nor

Not veryconfident

Notconfident

at all

8%

46%

13%

30%

3%


76%

8%16%



50% of the respondents believe that civil liability willbe applicable to the KID disclosures, a further 25%being unsure.

The Directive calls for greatertransparency and the use of non-technical language in the KID.

Use of non-technicallanguage in the KID versusthe fund prospectus

The UCITS IV Directive states thatclaims for civil liability cannot be basedsolely on the KID unless it is misleading,inaccurate or inconsistent with therelevant parts of the prospectus.

Whilst this should provide comfort forasset managers, the concern thatliability may be attached generallyarises from doubts over the ability toensure consistency with the prospectusgiven the constraints around thecontent and format of the KID. “It willbe difficult to ensure that there are nodifferences between the KID and theprospectus unless the latter isrewritten” to be consistent with thewording of the KID.

The real challenge will be for thosecomplex funds where the prospectuscontains investment objectives that arewordy or formula driven. How will thesebe transposed into several lines andthe non-technical language required bythe KID?

Only half of the respondents think thatthe wording in the fund prospectus willnot have to be simplified to ensureconsistency with the KID.

Liability in respect to the KID

Given the challenges describedabove, it is not surprising that 50%of respondents are concerned aboutthe possibility of civil liability beingapplicable to the KID disclosures,despite what is written in the UCITS IVDirective.

Respondents believe that for the KID tofulfil its purpose, investors need to beable to rely on the information providedin it. There is concern that should theperformance fail to be as expectedbased on the risk profile, the fundmanager would need to “explain theperceived misleading information inthe KID”

A more radical view held is that fundhouses “usually make the commitmentto publish reliable information andagree to be liable for it”.

Concluding thoughts

As investors are likely to rely on theinformation disclosed in the KID, thisraises the question as to how fundhouses will ensure they can deliver ontheir commitment to provide accurateinformation.

Time is limited to ensure they haveappropriate resources and effectiveprocesses and controls to ensure theproduction of accurate KIDs on a timelybasis. Further complexities arise whenthe fund house has outsourced thefund accounting or performancemeasurement to a third party, as theywill have to rely on these third partiesto provide the relevant information.

Asset Managers may involve furtherinternal resources such as internal auditor may seek external comfort from theirauditors or other third parties.


Is civil liability likely in respect to the KID?

Verylikely

Quitelikely

Neither/nor

Quiteunlikely

Veryunlikely

Don’tknow

17%

25%

33%

11%14%

0%

Do you believe that the use of non-technicallanguage in the KID will result in the need forsimplification and rewording of the language inthe Fund Prospectus?


43%51%

6%



58% of respondents have not considered the costimplications of changes to their systems andcontrols to implement the KID.

KIDs are to be produced withinformation as of 31 December eachyear and it is likely that they will need tobe produced in most cases for eachshare class. They have to be translatedinto the languages of the countries in towhich the share class is distributed.The Committee of European SecuritiesRegulators (CESR) recommends adeadline of 35 calendar days forupdating the KID information andhandling of material changes. Theproduction of the KID, as well as themonitoring of material changes thatwill require a new KID to be produced,will require the implementation of newcontrols and processes.

For instance a fund house with arange of 50 funds with five shareclasses each, that distributes all fundsin five countries will need to produce ata minimum 1,250 KIDs each year.Should material changes occur such asto charges or to the SRRI, it may bethat this number jumps to 2,500 to3,750 KIDs per year. This will havecost implications for asset managersand funds.

Cost implications

However, 58% of respondents havenot considered the cost implications ofchanges to their systems and controlsto implement the KID.

Those that have considered the costimplications think that “the productionof the KID will be a significantresource drain”. This is seen as adisadvantage, especially for fundhouses with a large institutional investorbase, as it is unlikely that institutionalclients will be relying on the KID tomake investment decisions.

Training of distribution staff

73% of respondents believe thatthere will be a need to train distributionstaff on how to read and use the KID.However, the view is held that“the document will not be verycomplicated to understand bydistribution staff, hence that trainingwill not be difficult”.

Where a fund house uses third partiesfor distribution (e.g. banks, IFAs ornetworks), only 38% think they need totrain third parties how to read and usethe KID. This is due to the view beingheld that the KID will be a standardisedpaper and therefore third partydistributors “should already be familiarwith the document”.

Concluding thoughts

It is surprising that less than 40% ofthe respondents have considered thecost implications of preparing the KID.For fund houses that produce financialinformation in-house, the productionof the KID with result in pressure onresources in January and February,historically already a time of resourceconstraint. Also, they will be looking todevelop an automated solution as thevolume of KIDs required (generally oneper share class), makes manualproduction impossible.

For those that have outsourced theproduction of financial and performancedata, they will need to review existingservices level agreements and workwith their third party providers to comeup with a workable solution.

In any case, the production of theKID will require careful planning, andwill have resource and cost implicationsthat should be assessed and reviewedas soon as possible to ensure assetmanagers are ready to meet therequirements.


Have you started to consider the cost implicationsof changes to your systems and controls toimplement the KID?

There will be a need to train your distribution staffon how to read and use the KID

Stronglyagree

Agree Neither/nor

Disagree Stronglydisagree

11%

62%

13% 11%3%


36%

58%

6%



Investment management companies haveidentified many KID requirements that they believeare challenging.As a final question in the survey, respondents were asked to highlight the most challenging KID rule to observe from theperspective of an asset management company. The following reflects the results in relation to the choices provided.

There is a wide spread of results, suggesting that respondents see numerous challenging aspects regarding the productionof the KID. Respondents also commented that they would have liked to have highlighted several boxes, meaning that severalof the above are regarded as equally challenging.

Concluding thoughts

These questions have highlighted that fund houses are concerned about a large number of different requirements relating tothe production of the KID.

This is consistent with the remainder of the survey. Respondents still have not considered all of the requirements, and thosethat have are identifying potential issues such as availability of resources and cost implications.

Fund houses should also assess when they need to start producing the KID. Even though this part of the Directive has beengrandfathered until 1 July 2012, the questions remains whether funds and / or sub funds being launched post I July 2011require a KID – if they do, fund houses and asset serving firms need to be operationally prepared for the KID by June 2011.

In order to avoid being caught out by the KID, it is essential that fund houses start assessing the rules and requirements andthe implications they have on their processes and controls now.

Percentage of respondents

24%The number of KIDs

Monitoring the risk indicator, and inherent updating of the KID

The risk indicator methodology

Disclosing the funds’ investment policy in “non-technical language”

The requirement of the yearly update of the KID within 35 calendar days asfrom 31 December

24%

19%

16%

14%


ContactsIf you would like more information about this survey or the KeyInformation Document, please contact any of the following or yourusual PricewaterhouseCoopers/EFAMA Contact.

Thierry BlondeauRegulatory & UCITS IV Project LeaderPricewaterhouseCoopers (Luxembourg)+352 49 48 48 5779 [email protected]

Sally CosgroveUK Funds & UCITS IV LeaderPricewaterhouseCoopers (UK)+44 20 7804 0669 [email protected]

Peter De ProftDirector GeneralEFAMA+32 2 513 39 [email protected]

Graziella MarrasSenior Policy AdvisorEFAMA+32 2 513 39 [email protected]

Ken OwensAsset Management Regulatory& UCITS IV LeaderPricewaterhouseCoopers (Ireland)+353 1 792 [email protected]


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