Insurance Europe — alongside several other financial sector associations — raised serious concerns in response
to a consultation conducted by the European Commission on planned
changes to the Packaged Retail and Insurance-based Investment Products
(PRIIPs) framework.
The Commission has recently adopted
amendments to the PRIIPs Regulation and the Undertakings for Collective
Investment in Transferable Securities (UCITS) Directive. However, in
contrast to earlier plans, it has postponed the adoption of the revised
Regulatory Technical Standards (RTS) to 7 September 2021.
Despite
this fragmented process, the Commission intends to maintain 1 July 2022
as the date that both the new Level 1 and Level 2 requirements apply to
product manufacturers, which would leave them with too short a period
to implement the new rules.
Implementing these changes
involves numerous departments and competences to interpret the new
requirements, gather new data, properly plan and make changes to IT, and
to adapt training for staff and distributors. It also requires
extensive dialogue between insurers and many stakeholders, such as asset
managers when they are UCITS providers.
The Commission’s too
short implementation timeframe could therefore lead to significant
challenges with implementation and even force operators to suspend the
distribution of certain products, which would be detrimental to
consumers’ participation in the capital markets.
Therefore,
to ensure an orderly implementation, the financial sector associations
called for a 12-month implementation period beginning after the adoption
of the RTS by the College of Commissioners, as this is the minimum time
needed for all products and all market participants. A reasonable,
synchronised application date for both the Level 1 and Level 2
amendments will be key.
The other signatories were the
European Association of Co-operative Banks (EACB), European Association
of Public Banks (EAPB), the European Banking Federation (EBF), the
European Fund and Asset Manager Association (EFAMA), the European
Savings and Retail Banking Group (ESBG) and the European Structured
Investment Products Association (EUSIPA).