Q&A Cross-border distribution of funds

The European Union has taken steps to facilitate the cross-border distribution of funds (both undertakings for collective investments “UCITS” and alternative investment funds “AIFs”) by introducing the Cross-Border Distribution of Funds package of measures (Directive (EU) 2019/1160 and a Regulation (EU) 2019/1156). The framework introduce rules regarding the provision of facilities, and rules on requirements around marketing communications. By the 2 August 2021 the Directive must be transposed into their national law, however Member States are at varying stages of implementation of the Directive. 


How will you provide facilities services?

We are in negotiations with a service provider to supply centralised facilities services to investors in the EEA. 


What changes to the marketing documents of the products offered do you intend to implement? For example, how will disclaimers or important notices in your product presentations change.

Our marketing materials adhere to existing legal and regulatory requirements, including MIFID II, UCITS and AIFMD, including the principle that marketing communication be fair, clear and not misleading. As such our existing marketing materials substantially satisfy the requirements of the Directive (EU) 2019/1160 with regard to cross-border distribution of collective investment undertakings and Regulation (EU) 2019/1156 on facilitating cross-border distribution of collective investment undertakings. We intend to implement some minor changes to the content of our marketing communication disclosures prior to 2 August 2021.


In what way you will take into account the requirement of a clearer indication that these are advertising documents.

All Schroders marketing material must be clearly identified as such.


What changes do you see in other promotional materials, such as films, podcasts or social media?

All Schroders marketing material must adhere to our marketing content rules, including that marketing materials (including films, podcasts or social media) be clearly identified as such and be fair, clear and not misleading. We do not anticipate material change in promotional materials such as films, podcasts or social media upon the coming into force of the cross-border distribution of funds framework.


Are you planning any changes to your websites?

We are not planning any major changes to our websites.


How are you addressing the requirements to provide information on investor rights (especially potential complaints and litigation)?

Investors’ rights to complain and certain information on redress mechanisms are made available to investors pursuant to our complaints handling policy and procedure. The summary of investor rights is available here.  As more information becomes available on the European Commission’s proposed Collective Interests of Consumer Directive we may further revise the investor rights information on our website.


When will these changes go live?

Changes will be implemented prior to the 2 August 2021 deadline as required.