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October 25, 2005
TO: INTERNATIONAL COMMITTEE No. 23-05
INTERNATIONAL OPERATIONS ADVISORY COMMITTEE No. 28-05
RE: DRAFT INSTITUTE LETTER TO THE EUROPEAN COMMISSION ON ITS UCITS
GREEN PAPER
As you know, the European Commission in July published a “green paper” on the EU
framework for investment funds and areas for improvement in the UCITS Directive.
Comments on the green paper are due to the EC by November 15th.
A draft Institute comment letter on the green paper is attached. The draft letter
applauds the efforts of the EC to foster an integrated and efficient market for investment funds
in Europe, but notes that the cross-border ideal inherent in UCITS has yet to become a reality.
The letter then makes four suggestions for ways in which the cross-border market for funds in
Europe could be improved:
• Streamline and simplify the notification procedure for passporting funds;
• Enhance the usefulness and comparability of fund advertising materials and
disclosure available at the point of sale;
• Improve the infrastructure for processing subscription and redemption orders;
and
• Adopt a common understanding or definition of “private placement” across the
EU.
We welcome your comments and suggestions on the draft letter. Please submit
comments by phone (202-371-5430), fax (202-326-5841), or email (rcg@ici.org) no later than
Friday, November 4th.
Robert C. Grohowski
Senior Counsel - International Affairs
Attachment (in .pdf format)