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FundAssist

Seamus O'Cuill
We would agree with this proposal.
See response to Question 12 re display. We would propose that a description of the particular risks for each of the three categories should be shown on the KID.
The use of probabilistic performance modelling is not generally favoured by UCITS manufacturers, who are by and large happy with the historical performance graph as shown in the current UCITS KIID. Feedback is that the compilation of these models may be complex, open to interpretation and lead to additional costs to the manufacturers.
In our view this section of the KID should have flexibility based upon the characteristics of the individual PRIIP. To be meaningful to the end investor, a 20 year with-profits life assurance policy should have a disclosure over a much different time frame than an investment in a retail cash fund.
We would propose that a clear and concise definition of the disclosure requirements be prepared for each of the main product categorisations as outlined in Section 1.6.2 of the Discussion paper.
Industry feedback from the UCITS manufacturers would indicate satisfaction with the display of one single risk indicator. General opinion is that the inclusion of more than one risk indicator may prove extremely confusing to the end investor.
The proposed inclusion of risk statistics is admirable but we would not be certain that terms such as Expected Shortfall or ELVaR would be readily understood by the end retail investor.
See response to Question 6. Should the proposal to use forward looking performance scenarios carry through we would propose that the disclosure would be based off an average of historical (actual or synthetic) performance over a pre-defined timeframe for each product. Should an optimistic or pessimistic scenario also be required, we would propose that a well-defined methodology for calculating these scenarios be contained in the upcoming consultation paper which would allow for ready comparison across PRIIPs.
UCITS manufacturers have strongly indicated that they would prefer to see the current cost disclosure requirements becoming standard for the PRIIPs KID.
UCITS manufacturers have strongly indicated that they would prefer to see the current cost disclosure requirements becoming standard for the PRIIPs KID.
Certain costs are conditional upon the length of time an investor may remain invested in the product. In order to make the cost structure clear to end retail investors it may prove necessary to illustrate more than one scenario, particularly where early exit costs and CDSCs apply.
See response to Question 12 re display. We would propose that a description of the particular risks for each of the three categories should be shown on the KID.
UCITS manufacturers have strongly indicated that they would prefer to see the current cost disclosure requirements becoming standard for the PRIIPs KID.
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