Above and beyond the production aspects of the KID for PRIIPs manufactures, UCITs funds, which do not need to produce the KID until 2019, will also be immediately affected by the Directive. This is because the PRIIPs who wrap their products will need to collect extensive amounts of data to produce their KIDs and in the case of Multi Option Products (MOPs) they will need to have easy access to the UCITs KIID documents. The consequence is that UCITs funds who might have thought that their deadline was in 2019 are quickly realizing that the still have a large an important obligation to meet this year.

At the same time, certain "UCITS only" groups could be tempted to anticipate the deadline of 2019 and produce from 2018 onwards the new KID for their own customers in order to avoid any confusion due to the co-existence of the KIDs and KIID's. They could in this way benefit from the first mover's advantage.

In order to facilitate a logical medium for the collection (on the part of PRIIPs manufacturers) and distribution of the underlying data needed to produce the KID (on the part of the issuers of the instruments that are wrapped by the PRIIPs manufacturers) the PRIIPs European Working Group is in the process of defining an industry standard for data exchange. We fully support the initiative and our infrastructure handles the PRIIPs related data for our clients.

We also realize that different local jurisdictions or individual PRIIPs manufacturers might have additional or different needs that cannot be fully addressed by the emerging new data exchange template, and may have a series of special requirements for technical delivery protocols that may necessitate a great deal of flexibility within the area of data exchange.

Published: 05 September 2016