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 welcomes EIOPA’s consultation and the opportunity to share our views on EIOPA’s recommendations to develop an EU single market for personal pensions.

EFAMA supports the conclusions of EIOPA’s impact assessment:

• The standardization of key elements of a PEPP - as proposed by EIOPA in its advice - with space to accommodate the specificities of Member States, is the best policy option.

• It would be difficult to achieve full standardization via harmonization because this would require bringing all national regulations on PPPs to one level.