Make an informed decision

Now December is upon us, we are counting down to PRIIPs and MiFID II in days, rather than weeks or months.

Nine new questions are included in the latest version of the PRIIPs Q&As, published on 20 November, including a new section with a couple of questions on Multi-Option Products (MOPs).

Having successfully delivered, after lengthy negotiations, the European MiFID Template (EMT) for the fund industry to provide the product data to populate customer reports under MiFID II, the European Working Group (EWG) has issued guidelines to help fund groups with the population of the EMT.

MiFID II and PRIIPs may have been “just around the corner” forever, but we are now in the last quarter before both come into force at the end of the year.  And that three-month deadline may be creating a justified feeling of panic.

It took just over six weeks for the European Supervisory Authorities (ESAs) to add 14 new questions to the 72 they answered in early July and they’ve supplemented this version with detailed flow charts of the decision process for the risk and reward calculations.  With around four months to go, we expect the pace of updates either to speed up because answers are needed urgently or to dry up completely if everyone is confident they have everything they need.  Does anyone believe there are no outstanding questions?

With MiFID II kicking off in January 2018, the European Working Group of asset managers and trade bodies has been putting in a huge effort to produce a standard template to deliver their target market and costs & charges data to distributors.

In February this year, the European Supervisory Authorities (ESAs) issued draft technical advice on EOS PRIIPs, along with a consultation paper (CP) on their proposals. On the back of responses to that CP, they have now submitted their Joint Technical Advice to the European Commission.

Further to our blog last month, the FCA has now published its updated policy statement on MiFID II implementation.

Earlier this week, the European Supervisory Authorities (ESAs) published their much-anticipated Q&As on various aspects of the PRIIPs KID and the Commission also issued its draft guidelines on PRIIPs.

The latest version of the PRIIPs Regulatory Technical Standards (RTS) were published last month.  You would think that, with the amount of thought and debate that have gone into PRIIPs since 2014, the RTS would cover every situation and to have a clear rule for each.  But, sadly, that isn’t the case.