Making The PRIIPs KID More Consumer Friendly

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Arendt & Medernach
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Together with our regulatory consultants and investor services experts, we bridge the gap between legal/tax advice and its implementation. We deliver best-in-class services along our clients’ business life cycles.

The 450 legal experts of Arendt & Medernach have a wealth of experience in a wide variety of specialisations. Together, they are able to advise on a complete range of 15 complementary practice areas, including Investment Management, Private Equity, Banking and Corporate Law.

As part of its EU Retail Investment Strategy, the EU Commission is proposing targeted amendments to the PRIIPs KID aimed at improving the information disclosed within it.
European Union Finance and Banking
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As part of its EU Retail Investment Strategy, the EU Commission is proposing targeted amendments to the PRIIPs KID aimed at improving the information disclosed within it.

On 24 May 2023, the EU Commission published its EU Retail Investment Strategy (RIS) and put forward a package of legislative measures in the form of a proposal for a Directive as regards the Union retail investor protection rules (proposed RIS Directive), coupled with a proposal for targeted amendments to the Level 1 PRIIPs Regulation (PRIIPs Regulation).

The targeted amendments to the PRIIPs Regulation complement the measures on product disclosures to be made under the proposed RIS Directive. For more detailed information on the proposed RIS Directive, please click here_
In addition, the EU Commission also proposes to introduce a new section into the PRIIPs KID covering the environmental sustainability of the relevant financial product and its expected greenhouse gas emission intensity.

Improving consumer friendliness

To make the PRIIPs KID easier to read, the proposed amendments introduce a new section called 'Product at a glance'. In this section, PRIIPs manufacturers will be required to summarise and highlight information about the investment product type, its total costs, the risk indicator, the recommended holding period and the existence of insurance benefits set out in the PRIIPs Regulation.

The 'comprehension alert' will be removed. The EU Commission's view is that the alert was not sufficiently effective in warning retail investors against particularly complex products and, conversely, might have unintentionally discouraged retail investors from purchasing less complex investment products.

Amendments to the rules for presenting the costs of multi-option products (MOPs) are also proposed. The amendments suggest that retail investors should be provided with tools, including simulation tools, to access and compare the total costs of a relevant PRIIPs before they select a particular investment option.

Finally, the EU Commission wants to make using the electronic format more flexible, so that investors benefit fully from the potential offered by the provision of a KID in electronic format, for example by being able to customise the amount they wish to invest or the holding period, according to their preferences.

Improving disclosure about sustainability performance

The EU Commission proposes removing the existing reference to environmental and social objectives pursued by the investment product and replacing it with a new section called 'How environmentally sustainable is this product?'. The new section must provide the retail investor with a harmonised set of key information on the sustainability profile of relevant investment products. It builds on existing product disclosures. The European Supervisory Authorities (ESAs) will draft delegated legislative acts specifying the content of the new section.

Clarifications of scope

Targeted amendments to a number of definitions will further clarify the scope of the PRIIPs Regulation.

Next steps

The legislative proposal is now subject to scrutiny by the EU Parliament and the Council of the EU. Once adopted by the EU co-legislators, the proposed amendments to the PRIIPs Regulation will enter into force on the 20th day following its publication in the Official Journal of the EU and will apply 18 months after its entry into force.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Making The PRIIPs KID More Consumer Friendly

European Union Finance and Banking
Contributor

About Arendt

Arendt combines the entire value chain of services dedicated to Asset Managers, Banks, Insurers, Public Institutions and Private Clients operating in Luxembourg.

-Legal & Tax
-Regulatory & Consulting
-Investor Services

Legal & Tax

We assist clients in structuring and running their business from a legal and tax standpoint across Luxembourg. Our teams directly serve international clients or work in close collaboration with foreign partner law firms.

Together with our regulatory consultants and investor services experts, we bridge the gap between legal/tax advice and its implementation. We deliver best-in-class services along our clients’ business life cycles.

The 450 legal experts of Arendt & Medernach have a wealth of experience in a wide variety of specialisations. Together, they are able to advise on a complete range of 15 complementary practice areas, including Investment Management, Private Equity, Banking and Corporate Law.

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