EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
The Packaged Retail Investment and Insurance Products (PRIIPs) regulation requires a three-page Key Information Document (KID) when financial products (such as funds, structured products or unit-linked insurances) are sold to retail investors. The KID’s objective is to provide essential and standardised information to investors to allow them to make an informed investment decision. In essence, the PRIIP KID is the successor of the UCITS Key Investor Information Document (KIID), and is meant to replace it in the near future.
Before switching from the UCITS KIID to the PRIIP KID, fund managers want to ensure that the information provided is relevant and non-misleading. Due to the PRIIPs Regulation’s large scope, this is no easy endeavour. In our opinion, both goals cannot be fully achieved simultaneously and some trade-off will have to be found between meaningful and comparable information. This conundrum can only be solved by the outstanding review of the PRIIPs Regulation. In the meantime, EFAMA is providing industry feedback on how to best transition funds from the UCITS KIID to the PRIIP KID, ensuring that there is sufficient time for such a transition.
EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
EFAMA welcomes the ESAs’ official approval of the revised PRIIPs RTS and is now awaiting the Commission’s endorsement to have the RTS approved by the European co-legislators.
Originally, the Commission had intended to endorse the revised RTS by Q1 2020. With less than nine months remaining until the 31 December 2021 implementation deadline, there is now simply not enough time for fund managers and other product manufacturers to properly implement the envisaged wide-ranging changes. We explain why in more detail below.
A flawed review process not tackling the heart of the issue
EFAMA has always made it clear that a revision of the PRIIPs Regulatory Technical Standard (RTS) falls short of conducting a proper Level 1 review. A review that is explicitly required by the Level 1 Regulation and is overdue for more than one year.
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
EFAMA and several other financial industry associations, raised concerns in response to a consultation conducted by the European Commission on planned changes to the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework.
The unexpected delay to the adoption of the revised PRIIPs RTS cuts the implementation period for the industry by more than two months. This leaves PRIIPs manufacturers and distributors with a too short period instead of the original timeframe of 12 months to implement the new rules.
EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
In support of our call for additional time to implement the PRIIPs rules, we have produced an infographic that summarises the challenges our members face replacing UCITS KIIDS with PRIIP KIDs. The infographic shows the many entities involved in the process and the steps required to prepare a PRIIP KID. Feel free to make use of this infographic.
Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, a dedicated working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels.