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Version date: 6 June 2019 - onwards
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ID 1088 (Last update: 06/06/2019)

Q. Is it possible to establish a UCITS which has both a listed share class (ETF) and an unlisted share class? What are my disclosure obligations?

A. Yes. However, such UCITS must be identified as a UCITS ETF. The listed share class must be identified as a listed share class. The unlisted share class must be clearly identified as an unlisted share class. The Responsible Person for a UCITS ETF must ensure the prospectus discloses the implications for investors depending on whether they are invested in the listed or unlisted share class.

The Responsible Person should

i. ensure the prospectus clearly sets out, in tabular format, the differences between investing in a listed share class and in an unlisted share class. At a minimum the following should be addressed:

A. Ability to deal in shares of each class on a dealing day. For example,

i. investors in an unlisted share class can purchase shares directly from the UCITS ETF. Investors in a listed share class can purchase shares on a stock

Comparing proposed amendment...