Submission to ASIC on Prospectus Disclosure
- Date:14 Jun 2011
- Type:Policy Submission
This submission responded to ASIC’s request for comments on Consultation Paper 155 – Improving Prospectus Disclosure for retail investors.
Our submission supported clear, concise and effective prospectus disclosure but noted, among other things, that:
• the proposal for mandatory disclosure that a person was a director of a company which went into external administration during their directorship or within 12 months of them ceasing to be a director should be removed;
• the requirement to disclose details of a directors’ criminal convictions should only apply to matters which do not constitute “spent” convictions;
• the goal of clear concise and effective prospectus disclosure is contradicted by requiring detailed disclosure of fees payable within market expectations, in the upfront investment overview; and
• a good faith defence should be introduced to encourage incorporation by reference.
Download our submission to ASIC on Prospectus Disclosure (PDF 2.07MB)