ESA Joint Committee · priips-150 Final

Annex VII of the Delegated Regulation, Table 2 on composition of costs: Cost elements in the “composition of costs” table are to be presented assuming a 0% annual return which is consistent with the p

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

Annex VII of the Delegated Regulation, Table 2 on composition of costs: Cost elements in the “composition of costs” table are to be presented assuming a 0% annual return which is consistent with the presentation of the cumulated costs for the 1 year holding period in the table “costs over time”. What does this assumption mean for the presentation of performance fees. In most cases, performance fees in funds will not be accrued in case of net performance of 0%. Does this mean that a performance fee of zero will need to be presented in the “composition of costs” table and taken into account as such for the 1 year cumulated cost calculations, even if performance fees have been charged by the fund during the last five years?

Answer

The amendments to the Delegated Regulation do not intend to amend the method for calculating performance fees specified in point 24 of Annex VI. This is indicated in point 69 of Annex VI. Therefore, the costs shown in both Table 1 and Table 2 in Annex VII (consistent with the EUR amount for performance fees used in the calculation of Total costs in the first column of Table 1) should reflect the average over the last 5 years. As indicated in Annex VII, the narratives within Table 2, composition of costs, are examples. These might be adjusted, such as to the following: “The actual amount will vary depending on how well your investment performs. The estimation in this document includes the average over the last 5 years”.

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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