We thank CESR for the opportunity to participate in this consultation on the technical issues relating to Key Information Document ("KID") disclosures for UCITS. We welcome CESR’s interest in this matter and we share CESR’s desire for clear and accurate disclosure of information to retail investors in a form that helps them to understand a fund and to compare it to other funds that might be available to them. We consider our response to this consultation to be a continuation of our response to consultations CESR/07-6691 and CESR/09-047.
In this paper we present short answers to the questions that CESR asked in its consultation paper and some additional comments, which we hope CESR will find helpful. We have included references to relevant pages and paragraph numbers in CESR's paper.