The European Banking Federation, Insurance Europe, the European Fund and Asset Management Association (EFAMA) and the European Structured Investment Products Association reconfirm their full support for the objectives of the PRIIPs initiative. In light of consumer protection, the PRIIP Key Information Document (KID) can be a valuable tool enabling retail investors to compare products and, hence, make informed investment decisions.

EFAMA would like to make positive use of the opportunity to comment on the Commission recommendation dated 28 January 2016 on the implementation of measures against tax treaty abuse as well as on the implementation of TRACE for the purpose of simplifying withholding tax (“WHT”) procedures.

EFAMA welcomes the opportunity to provide comments to the ESMA Consultation Paper on the technical advice to the European Commission on the Benchmarks Regulation. EFAMA also welcomes a number of clarifications and improved points that ESMA is providing in its Consultation and draft Technical Advice since its previous Discussion Paper.

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.