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 continues to support the overarching aim of the PRIIP KID as a single pre-disclosure document for all types of investment products.
EFAMA believes that the ESAs Joint Call for Evidence on PRIIPs and any subsequent proposals for revision of the PRIIPs Regulation should come after assessing in practice the revised PRIIPs RTS to be implemented from 31 December 2022, both to retail AIFs and UCITS.
We welcome yesterday's vote by the European Parliament plenary formally adopting two ‘quick fixes’ for PRIIPs (Packaged retail investments and insurance-based products) and UCITS (Undertakings for Collective Investment in Transferable Securities).
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
The European PRIIPs Template v2.0 (EPT) incorporates the necessary changes based on the revised PRIIPs RTS, published by in the Official Journal of the European Union in December 2021.
The EPT is intended to be used for products sold from January 2023 onwards. It is important that data contained in the EPT is communicated by asset managers to insurers in good time before this date, bearing in mind any national market specificities.
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This year’s Investment Management Forum featured an incredible number of high-level speakers and thought-provoking discussions.
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We welcome yesterday's vote by the European Parliament plenary formally adopting two ‘quick fixes’ for PRIIPs (Packaged retail investments and insurance-based products) and UCITS (Undertakings for Collective Investment in Transferable Securities).
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.
