ICI Supports CESR Proposal for Key Investor Information Document, February 2008

Washington, DC, February 19, 2008 - ICI has long supported clear, concise disclosure that investors would be able to understand and use. ICI recently submitted a comment letter in response to the Committee of European Securities Regulators (CESR) who published a proposal recommending a shortened disclosure document for UCITS, which are European mutual funds that can be marketed in all European Union countries.

Background
Last October, CESR published a consultation paper with recommendations on mutual fund disclosure reform. The core proposal is for a two-page ``Key Investor Information'' (KII) document that would replace the current UCITS (Undertakings for Collective Investment in Transferable Securities) simplified prospectus. ICI applauded a similar proposal by the SEC in November 2007.

We commend the efforts of CESR to address the need for standardized performance for funds.
We commend CESR's efforts to enhance risk disclosure for funds but have reservations with the proposal for a quantitative or synthetic risk indicator.
We agree with CESR's concerns about the challenges of quantifying portfolio turnover costs and do not believe that CESR should require the quantification and disclosure of these costs.
We believe that CESR should consider allowing the KII to be available electronically or in paper.