Follow Us

Follow us on Twitter  Follow us on LinkedIn
 

16 May 2009

FBE concerned about calculation of a synthetic indicator for KID for UCITS


Responding to the CESR consultation EBF notes that an indicator based on past volatility has a limited validity as such and cannot be used for structured funds. CESR could consider deriving the synthetic indicator instead from value-at-risk models.

Responding to CESR’s call for evidence on technical issues relating to Key Information Document (KID) disclosures for UCITS, the EBF has some more fundamental concerns with regard to the calculation of a synthetic indicator. An accompanying narrative description is therefore indispensable to provide additional explanations and help investors interpret and put into context the information given in the narrative indicator.

 

The Federation points to the fact that an indicator based on past volatility has a limited validity as such. In addition, it cannot be used for structured funds. CESR could therefore consider deriving the synthetic indicator instead from value-at-risk models.

 

EBF also notes that as KID-style disclosure documents for other kinds of retail investment products are currently under discussion, the EBF considers that it might be necessary to reconsider the set-up of the UCITS KID.

 

The European Banking Federation calls on CESR to bear in mind that the fundamental objectives of the KID is to inform investors in a concise and simple way.

 

In some cases CESR considers a trade-off between a ‘more scientific’, and a ‘more understandable’ approach, EBF notes. Keeping in mind that the nature of the document as such is not scientific, it justified a priority to give preference to that option which is clearer and more easily understandable for less experienced retail investors, the Federation argues.

 

The full response is attached below.

 



© EBF

Documents associated with this article

EBF response on CESR call for evidence for KID disclosures for UCITS.pdf


< Next Previous >
Key
 Hover over the blue highlighted text to view the acronym meaning
Hover over these icons for more information



Add new comment