For new funds with performance fees, is it possible to refer to an appropriate benchmark for
estimating the relevant returns of a peer group as foreseen in Point 24(b)(ii) second subparagraph of
Annex

Question

For new funds with performance fees, is it possible to refer to an appropriate benchmark for
estimating the relevant returns of a peer group as foreseen in Point 24(b)(ii) second subparagraph of
Annex VI?
When computing performance fees for new funds, the relevant fund return shall be estimated using
the return of a" comparable fund or a peer group". The use of an "appropriate benchmark" as set out
in Point 16 of Annex IV could indeed be considered as a "peer group" under the requirements of Point
24(b)(ii) of Annex VI. If this “appropriate benchmark” is composed of other investment funds the
respective returns of which are calculated on the basis of net fund performance, the adjustment of
returns in terms of costs referred to in Point 24(b)(ii) second subparagraph of Annex VI is not needed.
(Answer provided by the ESAs on the application of the PRIIPs Delegated Regulation, revised on 21
December 2022)
11. According to Point 5(l)(i) the most recently available summary cost indicator shall be used. What is
meant by most recently available summary cost indicator?

ESA Joint Committee (EBA, ESMA, EIOPA) · Accepted Answer

The most recently available summary cost indicator is the one that has been calculated according to
Points 61 to 89 of Annex VI of the Delegated Regulation. Point 79 indicates that the cost figures shall
be calculated at least once a year.

For new funds with performance fees, is it possible to refer to an appropriate benchmark for estimating the relevant returns of a peer group as foreseen in Point 24(b)(ii) second subparagraph of Annex

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