ALFI response to the European Supervisory Authorities’ consultation on PRIIPs with environmental or social objectives

23 March 2017

The Association of the Luxembourg Fund Industry supports the promotion of a sound and transparent Responsible Investment market (or Sustainable and Responsible Investment - SRI).

ALFI however believes that the proposal should remain within the scope of advising on the procedures to be used to determine when a PRIIP KID can refer to specific environmental or social objectives:

• the advice should not add disclosure requirements;
• the advice should not amend the scope of MiFID II or IDD;
• the advice should not add to product rules; and
• the advice should suggest procedures, not exclude certain strategies. 

The SRI market has already a variety of acronyms. ALFI recommends not to promote the raise of a new “EOS PRIIPs” acronym, which we believe would contribute to making the market more difficult to assess for investors.

A grandfathering clause should be foreseen: existing funds should be given time to comply if they elect to indicate this in their KIDs.

Full response

© ALFI - Association of the Luxembourg Fund Industry