Can a PRIIP manufacturer supplement the information described in Annex IV, point 30, of the Commission Delegated Regulation for the pay-off graph to ensure that it is comprehensible and meaningful for

It is not possible to use the same approach as for call and put options and futures traded on a regulated market. The KID for an OTC derivative contract should be drawn up indicating the relationship with the underlying asset, the type of underlying asset, the currency of the notional amount, the underlying value of the contract, a representative term, price or interest rate, and any other relevant features such as a strike, barrier or guarantee. The content of the KID, including the performance scenarios and the cost information, should be based on market data that are representative for the market conditions applicable as long as the OTC derivative contract is made available to retail investors. This means that the KID should not be based on purely hypothetical data nor that it has to contain specific contractual data. In turn, this means that it could be acceptable, to draw up a single KID for a class or group of OTC derivatives that share the same relevant product characteristics, including those outlined in the first paragraph. Equally, a separate KID can be drawn up for each OTC derivative contract reflecting the bespoke offer to the retail investor. Where the KID does not reflect a bespoke offer, the guiding principle would be that there should be limitations on any differences between the information in the KID and the actual OTC derivative contract purchased such that the requirement for the KID to be accurate, fair, clear and not misleading and consistent with the binding contractual documentation can be satisfied. Regarding the possibility to draw up a KID for an entire class or group of OTC derivatives this would be acceptable only if the data used would be such that the difference between the figures (e.g. on costs) in the KID for the group and the corresponding figures that would have been included in the KIDs of each OTC derivative within that group would be less than the reasonably expected margin of uncertainty on these figures in general. For example, regarding the representative term, it could be acceptable to draw up KIDs representing different ranges of maturities for a derivative contract (e.g. one KID for the OTC derivative contract with a maturity up to 3 months, one KID for the OTC derivative contract with a maturity from 3 to 6 months, etc.). Regarding the applicable price or interest rate in this case this would need to be accurate within the margin of uncertainty referred to above for all of the OTC derivative contracts within the range of maturities for which the KID is prepared. In order to be fair and not misleading, it may be appropriate to present the information in the KID, such as the performance scenarios and the cost information, reflecting the worst outcome for the investor within the maturity range. In case of a material change of the market conditions such that the data on which the KID is based are no longer representative for the market conditions, the KID should be reviewed, if that OTC derivative contract is still made available to retail investors. If a KID is drawn up for a bespoke offer, the review requirements do not apply as that PRIIP is by definition no longer available to other retail investors.