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. The PRIIP KID is based on the already existing fundonly Key Investor Information Document (KIID) which gives us invaluable insights into how such a concise document can help investors make better investment decisions.
Nevertheless, after the publication of the European Supervisory Authorities’ (ESAs) final draft Regulatory Technical Standards (RTS) on 07 April 2016, EFAMA does not believe that the desired aims will be met. Comparability will not be achieved and there is a danger of investors, at best, being led to focus on the wrong issues and, at worst, being misled. Thus, it is in the interest of the European Commission, and the European Parliament and Council as co-legislators to carefully scrutinise the usefulness of the PRIIP KID in its current form and correct the mistakes being made.