Thierry will also speak to these issues with his his colleagues the 16th of june 2016 for our conference on « Ditribution des produits d’assurance »
Regulatory Consulting Deloitte
The final draft Regulatory Technical Standards (RTS) for Packaged Retail and Insurance-based Investment Products (PRIIPs), has been published on 7 April 2016.
The final draft RTS is an important milestone on the journey of preparedness for the implementation of PRIIPs as of 1 January 2017.
Following the consultation paper of 11 November 2015, the final draft RTS clarifies a number of key elements that remained open from the consultation paper. It strongly confirms the intention of the ESAs to issue further detailed guidelines, FAQs and “how-to-guides” providing implementation measures mainly regarding cost, risk and performance methodologies.
The final draft RTS confirms the following non-exhaustive key points:
- Exchange traded derivatives are in scope. However, special circumstances for the treatment of these instruments, including provision for a pay-off structure graph are foreseen.
- The introduction of updates to the cost section, in terms of presentation and clarity on types of costs to be factored into revised cost tables.
- Clarification on events requiring an updated or revised KID document, including a specification on the level of materiality for Risk and Performance revision.
- Further clarification on the methodologies to be used in calculating risk, cost and performance figures has been provided.
Furthermore it is noted that there are template changes in terms of inclusion of additional mandatory statements and narratives, not previously foreseen in the consultation paper of November 2015.
The next step for the Technical Standard is the approval of the European Commission, anticipated to be “before the summer break”.
Deloitte is in the process of preparing an analysis paper detailing changes, clarifications and amendments of this final draft.
Please contact them should you wish to receive a free copy of it.