The UCITS KIID is a document which works well, and it should only be replaced if an equivalent standard is introduced which does not require further amendments in a short time. Therefore, ALFI is rather firmly in favour of a broad review undertaken by the European Commission as envisaged by the legislation within two years’ time (following a postponement of the UCITS KIID exemption by two years via a quick fix).
Given that more text and graphs are suggested to be included, the length of the KID should be extended to four pages.
There is a need to align the PRIIPs KID Regulation to the MiFID II and IDD in terms of presenting costs and performances to avoid that non-professional investors are misled. Under MiFID II - and also under IDD - only costs “not caused by the occurrence of the underlying market risk” shall be aggregated and disclosed to clients. Hence, as it stands the PRIIPs transaction cost figures cannot be legitimately used for the purpose of cost disclosure under MiFID II and IDD.
The ESAs state in the introduction of the consultation that “it is necessary to limit the proposed amendments to the most pressing issues and those that facilitate the possible use of the KID by UCITS and relevant non-UCITS funds”. However, ALFI believes that another pressing and key issue has been overlooked. The current arrival price methodology for transaction costs results in misleading information for the investors. ALFI refers in this context to the explanations in EFAMA’s evidence paper (dated 23 March 2018 / 28 June 2018) and EFAMA’s suggestions to address the PRIIP KID’s shortcomings (dated 10 September 2018).
ALFI supports the submission of the European Fund and Asset Management Association (EFAMA).
Full response
© ALFI - Association of the Luxembourg Fund Industry
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