[17696]
June 22, 2004
TO: INTERNATIONAL COMMITTEE No. 35-04
RE: ITALY’S CONSOB PROPOSES RULES IMPLEMENTING UCITS AMENDMENTS
Recently, CONSOB (the Italian securities regulator) proposed rules that, among other
things, would implement the amendments to the UCITS Directive in Italy. Attached for your
information is a brief memorandum from Italian counsel describing the various proposed rules.
The proposed rules would provide for the simplified prospectus, eliminate the supplementary
document that was required for the marketing of foreign UCITS funds (“documento
integrativo”), impose new requirements for marketing of foreign UCITS funds, and provide for
the treatment of new sub-funds of grandfathered funds.
According to Italian counsel, the main issue for non-Italian UCITS funds will be the
introduction of a “prime distributor,” which will have the responsibility to provide certain
information in an appendix to the application form. The appendix would have to include
information that previously had to be included in the documento integrativo. Counsel
discusses the potential issues of cost, time and strategic implications for marketing non-Italian
UCITS funds in Italy under this new regime.
If you have any concerns with CONSOB’s proposed rules, please contact me at (202)
326-5810 or at jchoi@ici.org as soon as possible. Comments on the proposed rules are due by
July 8, 2004.
Jennifer S. Choi
Associate Counsel
Attachment
Attachment (in .pdf format)