|
|
EFAMA believes that PRIIPs’ ambitions were excellent and that, from the outset this proposal has seen the strongest show of support from European asset managers. A KID for PRIIPs is a powerful instrument to ensure that consumers receive the right information before making their investment choices, when it comes to this type of packaged investment products.
To put it simply, a KID should give meaningful, comprehensible and comparable information for investors to feel confident and make better investment decisions. The PRIIPs Regulation has, by and large, set up a good framework to achieve this objective.
When it comes to the KID Regulatory Technical Standards, many of their provisions fulfil the purpose of allowing a practical implementation, but EFAMA is discouraged to see that other important provisions simply go against the Level 1 objectives.
EFAMA acknowledges that the EU institutions have made efforts to reconcile various views and find workable compromises.
Throughout the two-year technical process, the final RTSs have benefited from a number of improvements. Unfortunately, these fall short of what the asset management industry would have expected, to the extent that the PRIIPs Regulation will not fully deliver on its original promises to retail investors and could end up being harmful to them.
In spite of repeated requests, EU co-legislators and regulators decided to discard some of the major concerns voiced by both European asset managers and consumer representative organisations. In this context, EFAMA particularly regrets that:
As a result of this, meaningful comparisons between different products will be made more difficult, if not impossible.