Primary tabs

Federation of French Insurers (FFSA)

Boris Christophe
It is understood that these key questions have been identified to describe the consumer perspective rather than for the purpose of being disclosed as such in the KID. It is important that the questions correspond to and do not go beyond the provisions of the PRIIPs Regulation. It is important that the questions do not carry too negative connotations as far risk is concerned.Taking risk could give more return.
It is not sure that this type of diffenciation between risks (market, credit and liquidity risk) is easily understandable for the average retail investor. It is important to avoid too complex information.


The main French market concern is that the risk indicator correctly reflects the caracteristics of the hybrid life insurance contracts (combining a with-profit fund and several units of accounts) which are the widespread contract.

As far as a with profit fund is concerned (“actif general” ou “fonds en euros” wich represents 83% of the life insurance contracts liabilities), we consider that there no market, credit and liquidity risks (capital secured at anytime, insolvency guarantee schemes, surrender value guaranteed at anytime), unless, in respect of credit risk only, the insurance company becomes bankrupt.

As far as unit-linked investments are concerned, the main risks that may be suffered by the retail investors are volatility risks and capital loss risk. Life insurer is the owner of assets. The undertaking of the insurer towards its customers in case of termination (or early termination) of the life insurance agreement relates to a number of units but not the value which may vary due to market fluctuations.



Besides, as far as credit risk is concerned for insurance-based investment products, the Solvency II regime already ensures the financial capability of insurers to fulfil their contractual obligations, even under stressed conditions.
In addition, in France, insurers’ credit risk is further reduced thanks to insolvency guarantee schemes which should thus be taken into account when assessing the credit risk.


It should be emphasised however that, as opposed to the consideration introduced in the discussion paper, the impact of inflation on the value of the PRIIP should not be included as one aspect of the market risk mainly because this feature is not included in pre-contractual information disclosure for other products (MiFID and UCITS for instance). In addition, inflation is not a risk that is inherent for PRIIPs but affects all investment products in the same way. Therefore, this information is not useful for consumers nor does it increase comparability or transparency of products.

It is important to recall that the PRIIPS regulation (cf. art 8 C) provides that “when developing the draft RTS the ESAs shall take into account the features of the PRIIPs so as to allow the retail investor to select between different underlying investments or other options provided by the product.”
So, the goal of the kid is not only to compare PRIIPS between them but to allow retail investor at precontractual stage to choose different underlying investments or other options.
The main French market concern is that the risk indicator correctly reflects the caracteristics of the hybrid life insurance contracts (combining a with-profit fund and several units of accounts) which are the widespread contract.

For insurance-based PRIIPs, French insurers do not support :

- quantification of market risk for a with-profit fund,
- quantification of credit risk and liquidity risk for a with-profit fund and unit-linked investments.

French insurers do not support VAr or EIVAr but rather “historical volatility “ like the SRRI which is already used by UCITS.


More generally :
It is important to achieve a balanced result whilst avoiding the elaboration of disproportionally complex measures. Qualitative measures and generic criteria, in parallel with quantitative measures, should also be taken into account to determine the appropriate risk category. Especially, for credit and liquidity risk, generic criteria should be used (for example, insolvency guarantee schemes). Only for market risk measurement, a combination of both quantitative and generic criteria can be used.

As the scope of PRIIPs is very wide, it should also be acknowledged that the inclusion of certain elements, relevant to one group of products, might be irrelevant for another set of products.

It is important to recall that the PRIIPS regulation (cf. art 8 C) provides that “when developing the draft RTS the ESAs shall take into account the features of the PRIIPs so as to allow the retail investor to select between different underlying investments or other options provided by the product.”
So, the goal of the kid is not only to compare PRIIPS between them but to allow retail investor at precontractual stage to choose different underlying investments or other options.
These should be addressed as costs only paid in specific situations or under specific conditions.
For unit linked and “multisupports “insurance-based PRIIPs, achieving to find an appropriate scenario can be very difficulty due to the different types and variety of units of account for the retail investor at the time of delivery of the KID.

Deterministic scenarios could be more easily understood by consumers.
It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs).
Modelling will be needed and the general principles of the models could be set at EU level.

Finetunning or detailing the assumptions at EU level (such as setting the initial amount invested), however, might prove to be very difficult notably because of (1) the different spectrums of products available in different markets and (2) the differences in investment behaviour and capital at expense across the EU. This finetuning should be in line with consumer behaviour at national level.

Setting similar assumptions for all products would most likely result in consumers not receiving relevant information. This is notably the case for insurance-based investment products providing additional benefits. As such, it is important that the level II measures do no result in information that might be confusing or even misleading to consumers.

In addition, as far as different investment behaviours are concerned, it is also of utmost importance to ensure that consumers are not directed away from certain products that match their interests and investments on the basis of a KID only because it is not tailored to the features of the products appropriately. For example, the average investment by a retail consumer could significantly differ from country to country as a result of investor behaviour and/or average purchasing power.

In this context,high-level general principles for the performance scenarios should be set at EU level, while the concrete application and assumptions to be used should be developed at national level by the different PRIIPs manufacturers in cooperation with the local supervisory authorities to ensure a certain level of comparability between the different products and within certain product classes. This would also ensure that the assumptions and methodology used do not impact the product development and ultimately the product design.
Again, it is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs).

The timeframe and other assumptions should be set in line with the product features, ensuring sufficient flexibility, and should be consistent with the recommended holding period which also tends to vary depending on various factors, including national market specificities.

Inadequate and irrelevant scenarios, which are not tailored to the product, would lead to additional complexity and confusion for consumers.
As a general remark, it should be kept in mind when developing performance scenarios, that these should be understandable to consumers. As such, a balance should be found between easing comparability and appropriateness to consumers’ needs. If a KID would have the sole purpose of having full comparability between all products used in Europe, there is a risk that the KID might not direct consumers to the products that are suitable given their own personal situation.

It can be already noted that monetary amounts could potentially give the impression that the consumer is receiving personalised information rather than general pre-contractual product information disclosed on the product manufacturer’s website.

It is of utmost importance that the information in the KID is balanced attributing equal importance to all its features, including insurance benefits that are included in the product.

Finally, the performance scenarios should be consistent with the information on costs included in the cost section of the KID so that none of the features of the PRIIP is accounted for twice.
For unit linked and hybrid insurance based Priips, presenting the performance net of costs can be difficult because costs can depend upon :
units of accounts choosen
amount invested,
performance
duration.



Then, there should be a sharp distinction between costs and premiums. Premiums (ie. payments directly financing the insurance cover benefits of a PRIIP) should never be considered as costs.

Moreover, it is important that the features of insurance-based investment products are taken into account appropriately. These products also include insurance benefits, such as capital guarantee, and benefits related to biometric risks such as death benefits, occupational disability, protection of dependants etc. It is crucial that these are not considered as costs. It is a price consumers pay to directly finance insurance benefits.
it is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs). In addition, it should not be forgotten that the PRIIPs document is limited to 3 pages.

In this context and in line with Solvency II requirements and other legislation as well as to ensure that the investor is not over-burdened with irrelevant information, the Regulatory Technical Standards should not require the presentation of more than three scenarios in the KID.
The summary risk indicator could be confusing.
We would prefer to have one figure per risk.
The performance visual element showing three scenarios in one graph would be the most useful presentation for investors as allowing clear comparison.

Similarly to the summary risk indicator, it is of utmost importance to ensure that the presentation of the performance scenarios remain neutral as far as the design, the colours and any terms used are concerned to avoid any negative visual connotations.

Since risk and reward as well as costs and performance are strongly correlated, a thorough consistent approach and a unifying presentation of these features are needed.

Furthermore, consumers should clearly be aware that an insurance-PRIIP proposes insurance benefits in addition to investment opportunities. This should be acknowledged and clearly described through generic criteria in the context of the performance, even if the benefits are not included in the quantative calculation of the scenarios.
No, we believe it would be too confusing for retail investors.
Similarly to the key questions related to consumers’ perspective on risk, the key questions on cost identified in the discussion paper in table 10 should not be disclosed as such in the KID. The only question related to the costs that should appear in the KID is “what are the costs?” as established by Article (8)(3)(f) the PRIIPs Regulation. Thus it is important that the questions correspond and do not go beyond the provisions of the PRIIPs Regulation.

In this context, it is understood that these key questions have been identified to describe the consumer perspective rather than for the purpose of being disclosed as such in the KID.

In addition, it seems pertinent to reiterate here that the terms and wordings of the questions introduced by the PRIIPs Regulation for the headings of the KID already carry some negative connotations. The regulators must be cautious to ensure that, in this context, the rest of the structure and presentation of the KID do not lead to an overly negative document.
There are important challenges not only on achieving a level playing field in cost disclosure but also in the correct definition of the cost term for insurance-based investment products (see reponse to question 16). It is believed that the cost term and a balanced presentation of the costs and performance are crucial. The costs for the insurance sector presented in Table 11 do not reflect adequately the specificities of the costs for insurance products:
First, as already mentioned, insurance-based investments products include insurance benefits such as capital guarantee, and benefits related to biometric risks such as death benefits, occupational disability, protection of dependents, etc. , in parallel to the investment performance. In this context it is important to ensure that the premium for the additional and parallel benefits is not considered as a cost.

The costs for managing capital investments should also be included in the cost for unit-linked insurance products.

The costs for managing the insurance cover are wrongly listed as investment related costs.

Surcharges according to methods of regular payment chosen should not be considered as costs. They compensate the overestimated interest rates of prospective calculation. Since not all premiums are due at the beginning of the year, the interest yield for the entire year should be reduced.
Again, for unit linked insurance based Priips, costs can depend on :
- units of accounts choosen
, - amount invested,
- performance
- duration.

There are also important challenges not only on achieving a level playing field in cost disclosure but also in the correct definition of the cost term for insurance-based investment products.
First of all, it should be sharply and clearly distinguished between costs and premiums. Premiums – that is payments that directly finance the insurance cover benefits of a PRIIP (such as death benefits, occupational disability, protection of dependants, etc.)– should not be considered as costs.
Moreover, it is important that the features and insurance benefits of insurance-based investment products are taken into account appropriately and in a prominent way.
The following specific features of insurance-based PRIIPs are crucial and should be taken into account:
solvency requirements behind the insurance-based investment products should be covered in the performance and risk section of the KID (lower starting points, less risk).
early redemption fees should not be treated as costs. These deductions are justified in accordance with actuarial principles and serve to protect the community of policyholders (e.g. against anti-selection). Then again, this issue should be better addressed in the section of the KID on surrender value.
look through costs are sometimes not known to the PRIIP manufacturer, e.g. if the underlying fund a PRIIP invests in is not obliged to disclose certain costs.

Finally, there is a strong correlation between costs and performance of the PRIIP. Therefore, an integrated presentation of both is necessary for the retail investors to understand the link between the two elements.

There are many challenges in presenting costs at pre-contractual level as required by the PRIIPs Regulation:

First of all, when developing a cost indicator, the regulator must be wary of not creating a methodology which could impact the product (adaptation of the cost structure of a product).

At the pre-contractual stage, when the KID is produced by the manufacturer, the latter would typically not have any information about the amount the retail investor will invest. The KID should in theory provide useful and relevant information for investors, regardless of whether they invest 1000€ or 100 000€. This is very difficult as costs may vary depending on the initial investment or on the options chosen/activated during the lifetime of the contract. Some products may have a cost structure which will proportionally decrease costs when the amount invested increases.

In addition, without knowing the initial investment, it would not be possible to give both monetary amounts and percentages of all future costs:
A manufacturer may know that it will be charging a 2% management fee every year, but the monetary figure (in €) will depend on the amount invested.
Similarly, there might be a fixed 100€ entry fee but it will be impossible to show this as a percentage of the investment before the amount of the investment is known.

Furthermore, when the KID is drafted by the manufacturer, the manufacturer does not always know about the length or duration of the investment /contract: different durations may be available to retail investors. Costs may also vary depending on the duration of the investment.

Some legal clarity is also needed on:
The type of costs to be disclosed - At this stage, it remains unclear what costs that should be disclosed as the PRIIPs Regulation uses vague terms such as “indirect costs” and “direct costs”
how costs of different nature are expected to be aggregated - There might be a fixed entry cost of 100 euros regardless of the amount invested coupled with a fixed management fee of 0.5% per year and an early termination cost which can be either a fixed amount or a percentage of the investment value at the time of termination

To solve most of these issues, different cost disclosure formats, assumptions and techniques should be used for products that have different specificities or that are targeted at different consumers.

For unit linked and hybrid insurance based Priips, costs depends on the nature of underlying funds, amount invested, proportion in the investment, performance, options of guarantees chosen, length of the investment.
To solve these issues, a generic example for a fixed amount invested, according to a repartition in different funds for a year without any option of guarantees should be used.
The costs should be disclosed pursuant to French regulations (such as in the “encadré”). Disclosing both direct and indirect costs may in our experience be confusing for the customers and given the length of the KID (3 A4 pages), it may not be possible to indicate the various layers of indirect costs, depening on the various investment options. In addition, only internal costs should be disclosed, as external costs may not be known (or not with sufficient certainty and accuracy) by the manufacturer.
Those methods are irrelevant for insurance products.
These should be taken into account in the ongoing costs. Often these are included in the administration costs. Should this not be the case, assumptions will be needed.
It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs).

The main challenge would be to find a similar format for products that have totally different costs specificities. It should be acknowledged that often these products are not substitutes and therefore the format should not necessarily be exactly similar if it is in the interest of consumers.

As pointed out in table on pages 19 and 20, the information contained in KID should be comparable for different PRIIPs products and its representation should be consistent robust and stable. Since the insurance-based investment products have terms that sometimes last over decades, only annualised costs could achieve the above mentioned qualities of a cost representation. This becomes particularly obvious if products that have a term of 3 months are compared with products that have duration of 30 years. Therefore, the representation of annualised costs together with a reduction in yield approach is the most appropriate method for the cost representation, which is also very useful and understandable for the consumers.
Key challenge in standardising the format of cost information is to be able to answer to the only question that consumers are interested in wich is : how much will this product cost me
It is believed that option 5 could be a good starting point should it present the total cost in monetary terms per year (annual average) rather than for the whole investment period. Indeed the specificities of the insurance-based investment products (ie. very long duration) should be duly taken into account. Insurance Europe agrees with the discussion paper when it reads: “not all PRIIPs will have the same holding period, which may reduce comparability” (page 62). As such, an option presenting the total costs for the whole investment period would not allow for an effective comparison between, for example, a product with a few months investment period and one characterised by a 35 years investment period.

In light of the above, option 5 seems simple and precise as well as taking into account the PRIIPs Regulation (ie. split between entry, ongoing and exit).

It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs). The most consumer-friendly approach to address this issue in practice could be examined during the consumer testing exercise.

Finally, costs and peformance scenarios are strongly correlated. A thorough consistent approach and a unifying presentation of these features are needed (see response to question 14).
In the interest of ensuring that the KID is usable for consumers, risk indicators should be as clear as possible for consumers. The market, credit and liquidity risks should thus not be aggregated.

Rather it is believed that the market risk should be the only risk captured by the summary risk indicator through quantitative measures as well as qualitative and generic criteria. This approach would also be in line with the UCITS SRRI.

Qualitative information regarding the credit and liquidity risks could be added within the narrative explanation of the risks which are materially relevant for the PRIIP and which cannot be adequately captured in the risk indicator if relevant for the product.
As ESA rightly point out in table on pages 19 and 20, the information contained in KID should be comparable for different PRIIPs products and its representation should be consistent robust and stable. Since the insurance-based investment products have terms that sometimes last over decades, only annualised costs could achieve the above mentioned qualities of a cost representation. This becomes particularly obvious if products that have a term of 3 months are compared with products that have duration of 30 years. Therefore, the representation of annualised costs (yearly average of total costs) together with a reduction in yield approach is the most appropriate method for the cost representation, which is also very useful and understandable for the consumers.

The most consumer-friendly approach to present the cumulative costs in practice could be examined during the consumer testing exercise.
It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and suitability for consumers’ information needs).

It should be taken into account that consumers are interested in what a product will cost them, not how these costs are constructed.
It would be of no use for consumers to receive such a break-down of costs as presented in Table 12. Should this be the case, this would not be an adequate and balanced trade-off between the PRIIPs Regulation aims for transparency and usefulness for consumers. In addition, it should not be forgotten that the PRIIPs document is limited to 3 pages. As such, it is understood that these costs have been identified for the purpose of the consultation rather than for the purpose of being disclosed separately as such in the KID.


Only “entry and exit charges”, “ongoing charges”, and “any charges taken from the PRIIPs under certain specific conditions” should be disclosed in order to provide useful information to consumers. However, it should already be noted at this stage that it would not be feasible to include the latter in the cost indicator. As such, these costs should be presented separately.

The specificities of the insurance products should be duly taken into account particularly for the costs structure (e.g. long duration of the PRIIP). As such, a different KID template should be used for insurance-based investment products. This could be a solution to ensure that consumers have all the elements to compare the different PRIIPs products.
Standardised information on the PRIIP manufacturer’s contact details (including a webpage and a postal address) and on competent authorities would be relevant to consumers whilst reaching the objective of the KID to ensure that the information provided is concise and relevant.

In addition, the date at which the KID was developed should be referenced in addition to a disclaimer stating that it has been developed according to European standards and under the authority of the national/European authority.
The comprehension alert would lose its value and would not help consumers if it was used for a wide range of products including some that should not fall under its scope. At this stage, the criteria set out in recital 18 are falling short of bringing legal certainty as to which products’ KIDs should bear such a comprenhension alert. Thus, there is a risk that PRIIPs manufacturers face a situation where uncertainty bring them to disclose the comprehension alert although these products should not bear it.
A classification according to the legal type seems to be appropriate.
Considering the requirement to disclose the objectives of the PRIIP and the means of achieving them according to the Article 8(c)(ii), no other classifications other than the legal type are necessary.
It is important to keep in mind that the document must remain concise (limited to 3 pages) to ensure that the information remains relevant to consumers.

It is important to remind that the PRIIPS regulation (cf. art 8 C) provides that “when developing the draft RTS the ESAs shall take into account the features of the PRIIPs so as to allow the retail investor to select between different underlying investments or other options provided by the product.”
So, the goal of the kid is not only to compare PRIIPS between them but to allow retail investor at precontractual stage to choose different underlying investments or other options.

For the “objectives and means of achieving them “section, a broad narrative description could be relevant with references to other more detailed precontractual document.
It is important to keep in mind that the document must remain concise (limited to 3 pages) to ensure that the information remains helpful for consumers. The information already foreseen in the PRIIPs Regulation will already take some space. One KID per type of PRIIPS would be most helpful and should enable the manufacturers to prepare adequate KIDs for their customers.
It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and appropriateness for consumers’ information needs).

However, the provisions should not be too narrow or too specific so that the types could encompass the maximum useful number of retail investors. The aim of the product (ie. capital building for instance could be provided.
Insurance-based investment products have per se an insurance component.

A KID should be understandable to consumers. Consumers should be informed that, in addition to offering an investment opportunity, an insurance PRIIP (unlike other PRIIPs) provides for additional protection such as capital guarantee and protection against biometric risks (such as death benefits, occupational disability, protection of dependants, etc.).

Therefore, it is of utmost importance that they are presented in a prominent manner in the KID, ensuring that the total picture of a PRIIP is balanced. The presentation of insurance related benefits should not fall short in the KID.
The beneficiary clause in case of death should also be explained and enlightened.
Furthermore, to ensure comparison between different PRIIPs, it is important therefore that where there is an insurance cover, this is explained and for products that do not have an insurance cover, this is also indicated in the KID.
Life insurance-based investment product depend on life duration of the insured person. The term is therefore not known at the outset, when the KID is drafted and published.
Consumers should be informed that, in addition to offering an investment opportunity, an insurance PRIIP (unlike other PRIIPs) provides for additional protection such as capital guarantee and protection against biometric risks (such as death benefits, occupational disability, protection of dependants, etc.).. It is of utmost importance that they are presented in a prominent manner in the KID, ensuring that the total picture of a PRIIP is balanced. The presentation of insurance related benefits should not fall short in the KID. The beneficiary clause should also be mentioned.
The manufacturer could include its policy and procedures regarding complaints on its website and indicate that this is the case to the consumer at the pre-contractual stage.
A link to a webpage of the manufacturer should appear in this section.
Yes,

It is important to remind that the PRIIPS regulation (cf. art 8 C) provides that “when developing the draft RTS the ESAs shall take into account the features of the PRIIPs so as to allow the retail investor to select between different underlying investments or other options provided by the product.”
So, the goal of the kid is not only to compare PRIIPS between them but to allow retail investor at precontractual stage to choose different underlying investments or other options.
It is difficult to answer to this question because the precise presentation and content of the kid is not known without RTS. Thus, it is difficult to say if it is impossible to deliver a stand -alone document with the 3 page limit on length.
In France, unit-linked life insurance contracts and hybrid life insurance contrats (combining a with-profit fund and several units of accounts) represents 66% of the existing contracts and 85 % of the new contracts.
There could be between a few and hundreds assets that may be selected. At the delivery of the Kid, a list of underlying assets that may back accounting units is drawn up. However new assets may be approved on regular basis (sometimes daily) by the insurance company and the list changes all the time. One of the reasons explaining such situation is that the life term agreement duration is much longer (human life duration) than the duration of many underlying assets (PRIIPS such as structured products, etc.).

For this type of contracts, it is necessary to give generic information about option and state where and how more detailed pre-contractuel information relating to the investment products backing the underlying investment options can be found (information stipulated otherwise in EU (Article 185 solvency 2 ) or French legislation).
For the “objectives and means of achieving them “section, a broad narrative description could be relevant with references to other more detailed precontractual document.

For the “risk –reward “section and the “cost” section, a number of examples might be included to illustratethe range of options.
For the “objectives and means of achieving them “section, a broad narrative description could be relevant with references to other more detailed precontractual document.

For the “risk –reward “section and the “cost” section, a number of examples might be included to illustratethe range of options.
Yes, this would be relevant for insurance-based investment products.
There is no secondary market for insurance-based investment products. The question is therefore irrelevant for such products.
Yes, in order to update the KID, all information on the investment options needs to be updated. It would be extremely expensive to update on a regular basis all KIDs. Such updates should be made only upon occurrence of major changes (e.g., new investment options, any changes in the costs…).
Manufacturers should make public their new KID on their websites. No other communication model presented in the discussion paper seems adequate and/or balanced. Since KID is pre-contractual and not personalised, an active communication model about a new/changed KID is not feasible.
The KID is not a personalised document. In this context, additional technical standards on the timing of the delivery of the KID are not seen as appropriate.
The insurance cover benefits and the beneficiary clause should also be mentioned in the KID.
It is important that an appropriate solution for the different objectives the KID is aiming to achieve is found (ie. comparability, legal certainty and helpful for consumers).

Anyway, ESAs should take into account what already exits at national level


It is, therefore, necessary that different templates are used for different types of PRIIPs. A classification according to the legal form of the contract or instrument seems to be appropriate. It is important that the KID only includes information which is relevant for the specific product. For example, the information should be tailored to the features of insurance-based product. Therefore, even a finer distinction between different products might be appropriate.
For insurance-based investment products, both types, i.e. single and regular payment are equally important. Therefore, there should be a possibility to tailor the KID to both features in an appropriate manner. A one size fits all approach should be avoided since it will lead to consumers receiving misleading information.

The different options should be explained in the section on pay-out options. This can be done narratively.
Given that the amount to be invested by the retail investor is not known at the time of developing the KID, it will be necessary to work with assumptions. However, here again, several difficulties arise: To make the information provided relevant to the maximum number of retail investors, there would need to be a wide range of assumptions based both on the amount invested and on the duration of the investment. Multiplying assumptions might however make any table provided in the KID less readable and therefore less understandable to consumers. It would also be difficult to set assumptions that would work for all products all over the European Union. First of all, some products are not destined for short-term investment or there might be a threshold or a ceiling to the money invested. Therefore, artificially setting assumptions (eg: 1 – 10 – 20 years and 1000 – 10000 – 100 000€) and obliging manufacturers to use assumptions which do not fit their products would not help consumers get a good overview of costs. The investors’ profiles are very different from one market to another and the average amount invested could be substantially different from one member state to another. The ESAs should thus consider and take into consideration national differences and specificities accordingly.
+32 2 894 30 95