The Financial Regulator has issued Policy Update 3/10 in which it has approved, with effect from 1 September, 2010 a change in policy in relation to the naming of sub-funds within an umbrella fund, such that reference solely to the name of the investment manager may be permitted in a sub-fund’s name.  The Financial Regulator had not previously permitted the sole name of the investment manager of a fund to be incorporated into the name of the fund or in the name of a sub-fund within an umbrella fund arrangement (except where the investment manager was majority owned by the promoter or by the parent of the promoter of the fund).  The Financial Regulator will now permit this in respect of sub-funds where the name of the umbrella fund contains the name or brand name of the promoter.  Where a supplement to the prospectus is published in respect of the sub-fund, the name of the promoter must be stated clearly on the supplement cover.

This welcome policy change reflects increased industry appetite for “open architecture” within fund ranges and the greater use by promoters of third party platforms.