UCITS IV - What needs to be done & new opportunities The UCITS IV Directive (2009/65/EC) will be implemented in Ireland by 1 July 2011. It has now been followed by many implementing measures which give detail of the new requirements. The new framework will present opportunities and will also involve revision of procedures and documentation. The Central Bank consultation on how the UCITS IV regulatory framework will be implemented in Ireland is expected to issue soon. The compliance implications for individual UCITS funds and for UCITS managers will only become clear when the Central Bank consultation has closed and final UCITS notices and guidance notes issue. In the meantime, a significant level of clarity has been achieved by the level 2 and level 3 measures which have issued to date. Revision of Documentation

UCITS funds and UCITS managers will need to be UCITS IV compliant by the deadline of 1 July 2011. UCITS funds and UCITS managers are likely to need to;
• revise the business plan to reflect more detailed and documented operating, administrative and accounting policies and procedures covering internal control mechanisms, lines of responsibility, internal audit function, conflicts of interest policies, rules of conduct to ensure ongoing fair treatment of investors, best execution, complaints procedures, data protection procedures, compliance function, etc. This update may prove to be relatively straightforward where the investment manager is MiFID compliant as the UCITS IV Directive seeks to align the provisions with the MiFID requirements.
• revise or adopt a risk management process.
• issue KIDs in place of the Simplified Prospectus for all new funds from 1 July 2011.
• issue KIDs in place of the Simplified Prospectus for all existing funds (although the timing of this is not yet clear).
• revision of the prospectus may be involved and amendment of the fund constitutional document may also be desirable where funds wish to avail of certain