In Annex IV, Case 3 for PRIIPs referred to in point 1 of Annex VIII without sufficient historical data and with no benchmark, or with a benchmark without sufficient historical data, or any other Categ

In Annex IV, Case 3 for PRIIPs referred to in point 1 of Annex VIII without sufficient historical data and with no benchmark, or with a benchmark without sufficient historical data, or any other Category 2 PRIIPs. In point 13 it is said to use a benchmark regulated by Regulation (EU) 2016/1011 of the European Parliament and of the Council. Is not that a contradiction? In point 15 it is said that in the case in which there is not an appropriate benchmark or proxy with sufficient historical data which meets the criteria set out in point 5 of this Annex for the PRIIP, performance scenarios shall be calculated in accordance with points 21 to 27 of this Annex using 15 years of historical returns of the PRIIP or an appropriate benchmark or proxy. 1) Does that mean we are to treat the PRIIP as a Category 3 product? 2) It seems contradictory that the regulation is asking to calculate performance scenarios in accordance with points 21 to 27 with 15 years of historical returns, when we have not been able to obtain 10 years historical data, either from the actual product or its appropriate benchmark If we do not have sufficient data to meet the amended performance scenario calculations, may we treat the PRIIP as Category 1 according to the definition in Annex II, point 4(c). Accordingly, its Moderate, Favourable and Unfavourable performance scenarios should be “reasonable and conservative best estimates of the expected values". If yes, we would like to clarify if the SRI calculation should be set at a “6” in the case where the product may have sufficient data for SRI calculation (e.g. 5 years monthly), but insufficient data for performance scenario calculation (e.g. 10 years historical returns not available). Regarding the calculation of performance scenarios, the description of “Case 3” above point 13 of Annex IV of the PRIIPs Delegated Regulation refers to a PRIIP which does not need to refer to a benchmark in the “What is this product?