Q&A - Alfi

Art 18
Q. Are these sample presentations of past performance acceptable?
A. Yes, we think that both designs are permitted but they are at the limit of what is acceptable in terms of their use of
colour.
Q. Is the following example showing multiple share classes in one KID linked to a benchmark acceptable?
% European Equity
60.00
40.00
20.00
0.00
-20.00
-40.00
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
European Equity - Share Class A - EUR -32.10 -20.60 -15.60 -7.40 -2.10 1.10 7.60 37.50 45.50 30.50
European Equity - Share Class B - EUR -30.50 -19.50 -11.50 -5.70 0.10 -1.20 6.50 35.90 46.70 29.50
European Equity - Share Class C - EUR -29.50 -18.90 -15.90 -9.10 -3.60 -2.20 7.70 34.90 44.30 28.50
European Equity - Benchmark -33.60 -20.60 -14.90 -10.30 -2.20 1.10 7.00 30.30 40.20 32.60
A. We think that the general idea of the table is acceptable but there are some aspects of it that are not acceptable.
The performance numbers should be stated to one decimal place; the font size is too small; we think that the use of
colour is at the limit of what is acceptable: the contrast between the colours is clear when the document is printed in
colour or monochrome but it becomes difficult to see when the document is copied on a standard office photocopier.
When they prepare multi-share class KIDs we recommend that practitioners take note of Recital 13 of the EU
Regulation 583/2010, which requires that the KID should not be "too complicated or crowded". Practitioners should
also take note of Art 18(2) of the EU Regulation 583/2010, which says that a benchmark may not be shown during
years in which a UCITS does not exist. In this case, for as long as one or more share classes existed, we think that the
benchmark may be shown.
ALFI KID Q&A, Issue 1112, 19 December 201116 February 2012 Page 26