The new wording in Article 2(2a)(b) of the ‘What is this product?’ section appears to duplicate the requirement already included in the RTS Article 6 (in the “How long should I hold it and can I take

The new wording in Article 2(2a)(b) of the ‘What is this product?’ section appears to duplicate the requirement already included in the RTS Article 6 (in the “How long should I hold it and can I take money out early?” section), specifically where Article 6(b) requires “a description of the disinvestment procedure and when disinvestment is possible”. Is it necessary to include the same (or broadly similar) wording in both places of the KID? It is necessary to include the information required by the legislative provisions in Article 2(2a)(b) and Article 6(b) of the PRIIPs Delegation Regulation in the ‘What is the product?’ and ‘How long should I hold it and can I take money out early?’ sections respectively. However, this does not mean that the same wording has to be used. In general, there are expected to be cases where the same product aspect or feature has implications for different sections of the KID. For example, the description of the product in the ‘What is this product?’ section might cover areas that are relevant in relation to the more specific sections on the product’s risks and RHP. Taking into account the aim to provide comprehensible information to retail investors and, in particular, Article 6(4) of the PRIIPs Regulation, manufacturers are responsible for considering the overall coherence and readability of the document. In this regard, techniques such as cross-references may be useful for the reader to help them navigate the document or avoid unnecessary repetition, but equally excessive use of cross-references is likely to undermine the readability of the document. It can also be noted that Article 3(2)(e) of the PRIIPs Delegated Regulation concerning the section on ‘What are the risks and what could I get in return?’ covers a case where it is necessary to include a reference to the section on ‘How long should I hold it and can I take money out early?’. Regarding Articles 2(2a)(b) and 6(b) of the PRIIPs Delegation Regulation, the requirements in Article 2(2a)(b) further specify those in Article 8(3)(c) of the PRIIPs Regulation that the section ‘What is this product?’ shall contain information about ‘the nature and main features of the PRIIP, including: (…) (iii) (…) investment horizon; (…)(v) the term of the PRIIP, if known’. As specified in Article 2(2a)(b) of the PRIIPs Delegated Regulation, the information on the nature and main features shall include the possibility of early redemption before the term. At the same time, Article 2(2a)(b) of the PRIIPs Delegated Regulation also indicates that the information on this aspect in this section is rather a statement than a detailed description, distinguishing between cases where it is possible to redeem units of the UCITS or AIF on demand (indicating the redemption frequency) and those where there is no possibility to redeem units on demand. For cases involving more specific conditions regarding the redemption frequency, such as notice periods, redemption gates, and other liquidity management tools, retail investors should be informed that redemptions might be limited, delayed, or subject to conditions, and that further details about these conditions are provided under the section ‘How long should I hold it and can I take money out early?’ Therefore, with regard to investment and disinvestment possibilities and procedures, the section ‘How long should I hold it and can I take money out early?