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[19367]
November 15, 2005
TO: INTERNATIONAL MEMBERS No. 32-05
INTERNATIONAL OPERATIONS ADVISORY COMMITTEE No. 31-05
RE: INSTITUTE LETTER ON THE FRAMEWORK FOR INVESTMENT FUNDS IN EUROPE
Attached is an Institute comment letter to the European Commission submitted today in
response to the Commission’s “green paper” on enhancing the EU framework for investment
funds. The green paper sought input on possible areas for improvement in the UCITS
Directive.
The Institute’s letter is strongly supportive of the Commission’s efforts to foster an
integrated and efficient market for investment funds in Europe. Toward that end, the Institute
suggests five ways in which the cross-border market for funds in Europe could be improved:
1. Streamline and simplify the “fund passport” – the notification procedure that
enables a fund to be sold outside of its home market;
2. Enhance the usefulness of disclosure available at the point of sale, particularly by
allowing funds and intermediaries to rely principally on the Internet for purposes of
communicating the required information to investors;
3. Enhance the usefulness and comparability of fund advertising materials through the
establishment of standardized performance methodologies;
4. Streamline the process by which Member States approve marketing plans; and
5. Improve the infrastructure for processing subscription and redemption orders by
encouraging industry to develop pan-European standards for order processing.
The Institute also recommends that the Commission establish a working group to
consider adopting a common understanding or definition of “private placement” across the EU,
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arguing that such a common understanding or definition could significantly streamline the sale of
cross-border investment funds (both UCITS and non-UCITS) to pension plans.
Robert C. Grohowski
Senior Counsel - International Affairs
Attachment (in .pdf format)
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website (http://members.ici.org) and search for memo 19367, or call the ICI Library at (202) 326-8304 and request the
attachment for memo 19367.