In July 2014, the E.U. adopted changes to its Directive on Undertakings for Collective Investment in Transferable Securities (UCITS), commonly referred to as “UCITS V.” Member states must implement UCITS V by March 18, 2016. In September 2015, the U.K. Financial Conduct Authority (FCA) issued a Consultation Paper seeking comment on its proposed rules to implement UCITS V. See “FCA Consults on Implementation of UCITS V Provisions Applicable to Managers
” (Sep. 17, 2015); and “FCA Proposes Changes to Authorized Investment Funds Regulation
” (Sep. 24, 2015). The responses the FCA received on the Consultation Paper were generally muted and concerned remuneration and disclosure requirements, as well as depositary rules. The FCA recently issued a Policy Statement which addresses those comments and makes final changes to its implementing regulations. This article examines the main provisions of the Policy Statement, including the transitional measures and operational difficulties that may impact UCITS managers and other regulated firms. For more on UCITS V, see “U.K. Government Proposes to Implement UCITS V Measures Applicable to Fund Managers
” (Nov. 26, 2015). For more on UCITS, see “Are Alternative Investment Strategies Within the Spirit of UCITS?
” (Jun. 8, 2012); and “The Implications of UCITS IV Requirements for Asset Management Functions
” (Oct. 13, 2011).