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EFAMA is supportive of the general objectives of the PRIIP KID Regulation. It is however concerned about the very limited time that product manufacturers will have between the final technical rules and essential guidelines being published and the deadline to produce Key Information Documents from 31 December 2016 onwards. Having provided extensive feedback throughout the ongoing Level-2 work, EFAMA seriously doubt there will be enough time for market participants to implement the final rules by the end of this year, as originally foreseen by the co-legislators.
Development of technical standards for the PRIIPs KID has turned out to be a complex project involving several iterations of highly technical consultations. A number of fundamental questions still remain unanswered at this late stage, while others possibly require additional guidance at Level-3. In the best-case scenario, the final RTS will be published in the EU Official Journal in Q3 2016, leaving only a few months for the industry to create a huge number of KIDs.
If insufficient time is provided to surmount these key operational challenges, PRIIP manufacturers will be unable to provide a PRIIP KID to retail investors, and they may face serious legal risks that will result in a de-facto ban on distribution of any type of PRIIPs from 01 January 2017.