KIID diagnostics

Deloitte KIID diagnostics is a battery of over 75 separate tests aiming to measure KIIDs’ compliance to the requirements.

The KIID is intended to inform the investor in a clear, transparent and concise fashion. Conciseness is ensured by the pre-defined format. Clarity is harder to achieve, involving language, interpretation and the simplification of complex processes.

Many attempt the exercise - few succeed at the first attempt. Deloitte has developed KIID diagnostics to measure KIIDs both quantitatively and qualitatively. It is a battery of over 75 separate tests that checks not only that all the information that must be supplied, is supplied in the prescribed fashion, but also the quality and coherence of that information. Few KIIDs that have been reviewed have measured up on all these tests. 

Our KIID diagnostics services include:

Global conformity of the KIID template
This service is to check the conformity of your KIIDs based on a sample of two. Compliance is checked principally vis-à-vis CESR guidelines, Commission Regulation 583/2010, local applicable laws and various investment association position papers.

Conformity of the narratives in the “objectives and investment policy” section
With this service we check the conformity of ‘objectives and investment policy’ text against KIID regulations, namely its ‘plain language’, structure and content. We shall also check the KIID’s consistency with reference documents such as the prospectus and financial statements.

Diagnosis of the on-going charges methodology
This service performs a conformity review of the on-going charges calculation methodology against CESR regulations.

Diagnosis of the “past performance” section
This service assists with ensuring that the ‘past performance’ section is compliant in narrative and format especially for structured funds and in the case of new share classes in existing sub-funds. It also reviews past performance methodology against CESR regulations; moreover we can review past performance calculations based on your pricing history.

Conformity of the narratives in the “Risk and Reward profile objectives” section
With this service, we verify the conformity of the ‘risk and reward profile objectives’ text against KIID regulations, namely ‘plain language’, structure and content.


Lou Kiesch

Lou Kiesch

Partner | Regulatory Consulting

Lou joined Deloitte in November 2001 as Director in the Risk Advisory department, where he currently heads up the Compliance and Regulatory Practice. Since June 2005, he is partner within Deloitte’s R... More

Xavier Zaegel, FRM

Xavier Zaegel, FRM

Partner | Capital Markets/Financial Risk Leader

Xavier is a partner within the advisory and consulting department and is the head of the Capital Markets practice in Luxembourg. As a market and credit risk specialist, he has been leading various ass... More