Nobody denies the value of a short document with key information for investors before they commit to a fund or product. But criticism of the calculations used in PRIIPs KIDs has been pretty constant since even before they hit the streets in January and has hopefully reached a level that can’t be ignored by the European Commission or the European Supervisory Authorities (ESAs).
First, we need to clarify that the IDD covers the distribution of two distinct types of insurance – non-life (general) insurance and Insurance-Based Investment Products (IBIPs).
Back in what now feels almost like pre-history, the European Working Group (EWG) came together to provide a standardised reporting template to deliver the data from asset managers to insurance companies for their Solvency II reporting and the Tri-Partite Template (TPT) was born.
The day has now arrived and KIDs are required for sales of all PRIIPs to retail customers. Many of those involved to date may finally be exhaling after holding their breath for the last few months ahead of the deadline over the festive period.
But don’t think it’s all over just yet!
Now December is upon us, we are counting down to PRIIPs and MiFID II in days, rather than weeks or months.
Nine new questions are included in the latest version of the PRIIPs Q&As, published on 20 November, including a new section with a couple of questions on Multi-Option Products (MOPs).
Having successfully delivered, after lengthy negotiations, the European MiFID Template (EMT) for the fund industry to provide the product data to populate customer reports under MiFID II, the European Working Group (EWG) has issued guidelines to help fund groups with the population of the EMT.
MiFID II and PRIIPs may have been “just around the corner” forever, but we are now in the last quarter before both come into force at the end of the year. And that three-month deadline may be creating a justified feeling of panic.
It took just over six weeks for the European Supervisory Authorities (ESAs) to add 14 new questions to the 72 they answered in early July and they’ve supplemented this version with detailed flow charts of the decision process for the risk and reward calculations. With around four months to go, we expect the pace of updates either to speed up because answers are needed urgently or to dry up completely if everyone is confident they have everything they need. Does anyone believe there are no outstanding questions?