Q. Regulation 85(2)(a) of the Central Bank UCITS Regulations sets out a requirement that the identifier "UCITS ET F" must be used in the constitutional document. How is this to be applied when an umbrella UCITS has some sub-funds which are UCITS ETFs and some which are not?
A. Question 2 of ESMA's Questions and Answers on ESMA's guidelines on ETFs and other UCITS issues provides that where an umbrella UCITS has some sub-funds which are UCITS ETFs and some which are not, the "UCITS ETF" identifier should be used at sub-fund level. Accordingly, any references in the constitutional document to a sub-fund which is a UCITS ETF should include the identifier "UCITS ETF".