ESA Joint Committee · priips-108 Final

[Question deleted] (Revised 21 December 2022) 3. Which form and name should the ‘specific information on each underlying investment option’, referred to in Article 14 of the Delegated Regulation, tak

Regulation
PRIIPs
Answered
2022-11-14
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

[Question deleted] (Revised 21 December 2022) 3. Which form and name should the ‘specific information on each underlying investment option’, referred to in Article 14 of the Delegated Regulation, take? The information on each underlying investment option should be specific. This implies that the document should be drawn up specifically to comply with Article 14 Delegated Regulation, that the document should only contain the information items listed in Article 14 Delegated Regulation, and that these information items should not be included in a document drawn up for another purpose. PRIIP manufacturers have the choice to draw up a single document containing the specific information for all underlying options of the MOP or to draw up a separate document for each underlying option of the MOP. For the information prescribed by Article 14 of the Delegated Regulation, this needs to follow the structure of the relevant parts of the template for the Key Information Document as set out in the Annexes to the Delegated Regulation, e.g. headings, tables and narratives descriptions. The name of the document should not be misleading and a name that is already assigned by law to another document should in particular be avoided. It is a good practice to use the name ‘specific information document’. (Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21 December 2022) 4. Will a MOP be able to rely on the PRIIPs KID published for a fund as the specific information document, as required in Article 10(b) of the Delegated Regulation? “Open architecture” products permit investment in any suitable investment vehicle and it would be impossible for a manufacturer of these products to produce a SID for every investment option. Also, as it would be impossible for the MOP manufacturer to post a SID for every fund on its website alongside the MOP KID, will it be possible to direct a retail investor to find the KID for the selected fund, as also indicated in Article 10(b) – “including a description of where the specific information on each underlying investment option can be found”?

Answer

For a MOP offering a fund as an underlying investment option, the specific information on that fund needs to comply with Article 14 of the Delegated Regulation. This includes “a statement on whether or not those costs include all of the costs of the PRIIP in the case that the retail investor invests in that specific investment option only” (point (d) of the first subparagraph of Article 14).

This Q&A is published by ESA Joint Committee (EBA, ESMA, EIOPA) and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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