EFAMA strongly supports the objective to provide retail investors with a key information document (KID) for all packaged retail and insurance-based investment products (PRIIPs). It is important that investors and their advisers throughout Europe are given meaningful, comprehensible and comparable information to feel confident about investing and to make sound investment decisions.

This memo covers investments in collective investment vehicles (CIV) in contractual, trust, or corporate form (simply referred as funds) from corporate and institutional investors acting on their own account (e.g. banks, life insurers, industry companies, etc.) and the accounting treatment of such investments under the upcoming IRFS 9 rules. While IFRS 9 contains many positive evolutions, many of our members have been warned by their client investors that IFRS 9 would change their attitude towards investing in funds.

EFAMA is grateful for the opportunity to comment on the OECD Public Discussion Draft related to concerns received by the OECD on previous discussion drafts related to the Report on Action 6, as to how the new provisions included in the Report on Action 6 could affect the treaty-entitlement of nonCIVs. We agree with the aim of the discussion draft to clarify any concerns in relation to the discussion concerning the treaty entitlement of CIVs / Non-CIVs.