Please let us know if you have any response which you would like to make to the consultation, or if you would like more information, either by e-mailing FundsGroup@algoodbody.com or by  letting your usual contact in the A&L Goodbody Funds team know. The consultation will close on 15 March 2011.

Anticipated timelines for revising documentation and ensuring compliance
The revised UCITS Directive must be implemented by Member States by 1 July 2011. At a practical level, and assuming that the consultation timelines do not change, we anticipate that

• Existing UCITS management companies will be required to submit revised business plans for review by Friday 29 April 2011
• Self Managed Investment Companies (SMICs) and UCITS management companies authorised from 1 July 2011 will be required to comply with all relevant requirements from their date of authorisation
• SMICs authorised before 1 July 2011 will be required to comply with requirements on rules of conduct and risk measurement from 1 July 2011 and will be required to confirm that their business plans have been amended accordingly by 1 July 2011. These SMICs will be required to comply with all applicable UCITS IV requirements by 1 July 2013.
• UCITS authorised from 1 July 2011 must use the key investor information document (KIID)
• UCITS authorised up to 1 July 2011 may use the simplified prospectus or SP until 30 June 2012 and must thereafter use the KIID. An existing UCITS umbrella which launches a new sub-fund after 30 June 2011 may elect to publish an SP or a KIID for the new sub-fund.
• Both UCITS and non-UCITS money market funds (including Qualifying Investor Funds) must comply with ESMA's guidelines on a common definition of European money market funds by 1 July 2011 (as previously flagged in the Front Page).The Central Bank have highlighted in CP 50, that an amendment to the prospectus of each money market fund to reflect whether it is a "short -term money market fund" or a "money market fund" will be necessary before 1 July 2011 and that draft prospectuses must be submitted by Friday, 29 April 2011.