Yesterday, FinDatEx published the new EMT v4.2. The new version includes additional fields concerning further details of ongoing costs for the UK market. The reason for this update is a statement from the FCA from November 2023. In this statement, the FCA expresses their concerns about cost disclosures by funds investing in other underlying funds and funds that invest in real assets such as real estate and infrastructure. This especially affects UK closed-end funds, because according to the FCA statement “these are pooled investments but are also bodies corporate and so have some features of companies as well as of funds. This can affect their cost base, as some costs incurred by listed closed-ended funds can in some cases be equivalent to costs incurred by commercial companies. Commercial companies are not subject to these costs and charges disclosure requirements. “
Please find the entire FCA statement at https://www.fca.org.uk/news/statements/statement-communications-relation-priips-and-ucits.
To reflect the FCA statement, FinDatEx has introduced the following new fields:
- 10000_Financial_Instrument_Indirect_Costs_Open_Ended_Ex_Ante_UK
- 10010_Financial_Instrument_Indirect_Costs_Closed_Ended_Ex_Ante_UK
- 10020_Financial_Instrument_Real_Assets_Costs_Ex_Ante_UK
- 10030_Financial_Instrument_Indirect_Costs_Open_Ended_Ex_Post_UK
- 10040_Financial_Instrument_Indirect_Costs_Closed_Ended_Ex_Post_UK
- 10050_Financial_Instrument_Real_Assets_Costs_Ex_Post_UK
- 10060_Does_Financial_Instrument_Produce_Client_Facing_Disclosures_U
While fields 10000 – 10050 are directly related to ongoing cost figures and the FCA statement, the field 10060_Does_Financial_Instrument_Produce_Client_Facing_Disclosures_UK refers to the SDR regulation, the UK equivalent of EU SFDR, and provides information if a there is a so-called Client Facing Disclosure (“CFD”) available for a fund.
The new EMT V4.2 can already be used but needs to be adopted latest by 30th June 2024 for the UK market. In the EU, both templates V4.1 and V4.2 can be used. The documentation can be found on the FinDatEx website at https://findatex.eu/.
Sources: FinDatEx, FCA, The IA
