ESA Joint Committee · priips-141 Final

In the case of subscription products, could the manufacturer include a reference to the variation (+/- Costs) due to variation in market conditions during the offering period?

Regulation
PRIIPs
Answered
2021-12-17
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

In the case of subscription products, could the manufacturer include a reference to the variation (+/- Costs) due to variation in market conditions during the offering period?

Answer

So, the client always will have detailed costs and what is the real margin of the manufacturer. No. A reference to potential variations in costs due to market conditions does not ensure accurate cost information for the client. According to Article 15 of the Delegated Regulation, if there is a relevant change in the costs of the product to be assumed by investors indicated in the KID, the manufacturer shall update the document to ensure the KID remains accurate. According to point 44 of Annex VI, in particular, where long offering periods or high market volatility exists, a criterion to update cost information shall be defined.

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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