On 8 November 2018, the European Supervisory Authorities (ESAs) issued a joint consultation paper concerning amendments to the Key Information Document (KID) for Packaged Retail and Insurance-based Investment Products (PRIIPs).
The proposed amendments are related to:
- Performance scenarios
- Other specific amendments
- Amendments arising from the possible end of the exemption in Article 32 of the PRIIPs Regulation
Stakeholders have an opportunity to comment on the proposed amendments to the PRIIPs Delegated Regulation. Comments can be sent to ESAs by 6 December 2018.
One of the changes introduced by the new European regulation is a distrinct separation between investment research fees and trade execution fees.
Veneziano & Partners have discussed the various aspects of MiFID II unbundling for U.S. market participants.
During the first 6 months of 2018, PRIIPsHub has executed a very successful implementation of its MiFID and PRIIPs related data collection services.
The implementation has included adding well over 100 distributors, including banks, fund of funds, platforms, insurance companies and wealth managers, consuming a variety of MiFID and PRIIPs related information. PRIIPsHub currently has over 90.000 EMTs in its database, along with over 42.000 EPTs and a wide variety of documents, including both KIIDs and KIDs, spanning a wide range of product types and from a wide variety of jurisdictions.
PRIIPsHub has also successfully implemented data and document push services for its asset manager clients, who are providing EMTs, EPTs and documents to over 150 recipients throughout Europe in most of the major countries.
If your company is looking for customized data or document collection services that can incorporate both UCITS, and different types of PRIIPs products in any relevant jurisdiction, contact us at [email protected] or call +45 2250 6867 for further details.
At the time of the MiFID II implementation deadline, at the onset of 2018, there was a very sharp focus on meeting regulatory requirements, primarily MiFID data in the form of the EMT. At the time, most issuers had a clear understanding that they would need to provide distributors with data that would allow for the sale of their products and in most cases managed to create the EMT and to make it available.
However, in terms of the EPT there was a much lesser focus on the part of the product issuers. One could logically attribute this to the notion that the EPT was not regulatory in nature and therefore was not a requirement. Naturally, this observation was technically speaking correct, but there were a significant number of business related challenges that arose because of the lack of focus on the EPT.
The most challenging situations in this case, were UCITS funds that had not seen that the EPT was necessary from a pure regulatory perspective and had therefore not produced the EPT. Certain asset managers were not fully cognizant of the business needs of PRIIPs that had wrapped their funds or included them in a MOP product, as there were clear scenarios where the PRIIP could not utilize Article 14.2, which allows them to link to the UCITS KIID. In such cases, the manufacturer of these PRIIPs would certainly need to receive the EPT, and in some cases, in a variety of languages.
There have also been a great number of Fund of Funds who have needed to gain access to the EPT, in order to calculate their charges. In the end, although their main preference had been to receive the EPT, many have opted to use the EMT for this purpose, as it was more readily available.
In both of the above cases, there has also been a large void in data from non-European funds, which the PRIIPs or fund of funds had invested in. This has caused some serious challenges for fund companies located in jurisdictions where they are subject to regulations that prevent them from publishing future performance scenarios, and has had a significant business impact. As a consequence we are now experiencing that some non-EU issuers are producing truncated versions of the EPT in order to meet minimum business requirements.
If your company needs customized EMT and EPT distribution services, contact us at [email protected] or call +45 2250 6867 for further details.