EFAMA firmly believes that the PRIIPs KID is a powerful instrument to ensure that consumers receive the right information before making their investment choices.

We have long argued that the draft RTSs, as endorsed by the European Commission, will not achieve the intended objective to make the KID helpful to consumers. They will at best confuse investors, at worst mislead them.

We find it important that the RTSs are amended in a satisfactory way, one that solves their current flaws - namely by allowing past performance and fixing the inaccurate calculation methodology of transaction costs. We trust todays adoption will result in amended RTSs that will help and inform consumers. The current draft RTSs do not.

EFAMA in no way would like to reopen discussions on the PRIIPs Level 1 Regulation. What is crucial now is to get the Level 2 PRIIP KID right - and this means amending appropriately the draft RTSs, while safeguarding and leaving untouched the letter and spirit of the Level 1 Regulation, save the necessary adaptations of the PRIIPs Regulation to allow for a postponement of its application date.

Market operators will apply the rules appropriately. The premise to do this is to know the final rules, and to have sufficient time to implement them. We want to be clear: there is only one reason why we find a delay absolutely essential, and this is because it is materially impossible and simply unrealistic for product manufacturers and distributors to meet the 31 December 2016 deadline. We urge the Commission to follow suit to todays call from the ECON in this regard.

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Notes:

About the European Fund and Asset Management Association (EFAMA):

EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 61 corporate members EUR 21 trillion in assets under management of which EUR 12.6 trillion managed by 56,000 investment funds at end 2015. Just over 30,000 of these funds were UCITS (Undertakings for Collective Investments in Transferable Securities) funds, with the remaining 25,900 funds composed of AIFs (Alternative Investment Funds). For more information about EFAMA, please visit www.efama.org