ESA Joint Committee (EBA, ESMA, EIOPA) Q&A Database

Is a look-through only required for underlying investments above a certain threshold within the portfolio of the fund of fund? When dealing with fund of fund or other multi-layer instruments, does the

PRIIPs

Some fees are paid from the fund/investors to the manager based on the narrowing of the share price to NAV discount on a closed-ended listed fund. Should this type of fee be classed as a performance f

PRIIPs

In the case of private Equity, infrastructure and other similar funds where the investments to be made by those funds are unknown at the date of creation/investment in the fund, how to anticipate cost

PRIIPs

Could you provide an example of the provisioned fees for specific treatment of gain and losses, which are referred to in Point 5 (d) of Annex VI?

PRIIPs

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

PRIIPs

What could be the ‘reference indexes’ mentioned in Point 21(c)(i) of the Annex VI of the Commission Delegated Regulation?

PRIIPs

- Guidance on the methodology described in Point 21(c)(ii) to estimate transaction costs: 3. What could be the ‘comparable information’ mentioned in Point 21 (c) (ii) of the Annex VI of the Commission

PRIIPs

According to Point 21 of the Annex VI of the Commission Delegated Regulation for PRIIPs that have been operating less than 3 years transaction costs may be calculated as an average of the actual trans

PRIIPs

Should transaction costs be calculated the same way in the ‘Composition of costs’ and the ‘Cost over time’ table? Yes, in both cases, transaction costs should be calculated according to Point 66 and t

PRIIPs

According to Point 33 (b) of Annex VI, the costs of the underlying shall be taken into account in the list of costs of PRIPs other than investment funds. How should this requirement be understood in t

PRIIPs

Is it correct to say that for the purpose of the Points 36 and the following provisions, while the fair value of the product needs to be in line with accounting standards, it does not have to be neces

PRIIPs

What value should be input into portfolio transaction costs of PRIPs other than investment funds?

PRIIPs

According to the Point 37 of Annex VI ‘If the PRIIP manufacturer is unable to distinguish the relevant implicit costs to be disclosed as referred to in Point 29 of this Annex using the difference betw

PRIIPs

Are portfolio costs for traditional endowment insurances to be taken into account in the summary cost indicator of the KID?

PRIIPs

Is it fair to assume that a EU-regulated UCITS fund will always meet the requirements under Annex II Point 46 (a) and (b) and thus the CRM for a UCITS fund will always be equal to 1. If not under what

PRIIPs

Should entry and exit costs under the table ‘Composition of costs’ of Annex VII be recalculated as an impact per year based on the recommended holding period instead of a RIY figure? No, the calculati

PRIIPs

Would a hedge fund that meets the following criteria be considered a Category 1 or Category 3 PRIIP?

PRIIPs

Is it possible for an insurance company to satisfy the criteria in Point 47 of Annex II, Part 2?

PRIIPs

Please clarify the requirement in Point 38 of Annex II, part II: where a credit assessment is not available under both (a) and (b), i.e. there is not both a credit assessment assigned to the PRIIP and

PRIIPs

How should derivatives be weighted when applying Point 40 of Annex II?

PRIIPs

In case a PRIIP is a fund of funds, where the underlying investment is a fund which is in turn investing in another fund, should we consider the funds in which the PRIIP is investing in directly as th

PRIIPs

Where the investor has access to a compensation scheme for the investment amount of the KID, is it correct to assume that credit risk is zero? It is not correct to assume that there is no credit risk.

PRIIPs

For a PRIIP with an MRM of 6, the aggregate SRI will always be 6. Therefore, is it still necessary to assess the credit risk for a PRIIP with an MRM of 6?

PRIIPs

In which situations does the credit risk of the underlyings of a PRIIP need to be assessed? In particular, a) what approach should be taken for stocks and UCITS investing in stocks? And b) If a positi

PRIIPs

A fully protected product can be allocated to MRM 1. Is this still the case if the underlying assets do not have the required minimum historical data, or is the product automatically allocated to MRM

PRIIPs

What is meant by unconditional protection of the capital (e.g. Point 24 of Annex II)?

PRIIPs

Are we right to assume that the bootstrapping of equity baskets should also be based on a principal component decomposition (at least for baskets of more than two underlyings)? On which rule should th

PRIIPs

The principal component analysis of Annex II, Point 23 ensures the consistent simulation of curves. Is it mandatory to use this method also for PRIIPs that depend on only one interest rate underlying,

PRIIPs

For products with an automatic early-redemption feature, the holding periods might differ for each of the simulations. What value of T, related to the formula for the calculation of the MRM, the lengt

PRIIPs

Does the formula in Annex II Point 17 use the simulated value of the PRIIP divided by its initial value? Should the calculation of VEV post-issuance be based on the ratio of the simulated value divide

PRIIPs

The MRM class determination for Category 3 PRIIPs, as specified in Annex II, Point 16, states that the “[…] VaR shall be the value of the PRIIP at the 97.5% confidence level […]”. Since the formula in

PRIIPs

Could you provide an example of the ‘dividends served by the shares held in the portfolio of the funds, shall the dividends not accrue to the fund’ mentioned in Point 5 (r) of Annex VI?

PRIIPs

If the recommended holding period (RHP) of the PRIIP is less than one year, how should performance and cost figures be presented in the KID? Point 45 of Annex IV and point 76a of Annex VI of the Deleg

PRIIPs

Is the provision in Annex II, Part 1, Point 14 (b) applicable where a fund has sufficient history?

PRIIPs

Could you specify which types of costs of capital guarantee provided by a third party guarantor are those mentioned in Point 5 (i) of Annex VI?

PRIIPs

While financing costs related to borrowing (provided by related parties)” are recognised as a recurring cost in Point 5(h) of Annex VI, could you confirm that overdraft charges on a bank account opera

PRIIPs

[Question deleted] (Revised 21 December 2022) 9. [Question deleted] (Revised 21 December 2022) 10. How should I calculate the transaction costs associated with an IPO or other offering of primary sec

PRIIPs

Can non-ETDs use the same treatment as ETDs?

PRIIPs

If the order is a limit order, should the arrival price be the limit order?

PRIIPs

Can a PRIIP manufacturer supplement the information described in Annex IV, point 30, of the Commission Delegated Regulation for the pay-off graph to ensure that it is comprehensible and meaningful for

PRIIPs

How should the requirement to use data of an appropriate benchmark/proxy be interpreted where there is no, or insufficient, price data for the PRIIP or the underlying value. For example: - Would an op

PRIIPs

In Annex II, Part 1, Points 9 and 10 it states that the minimum observation frequency is monthly but subsequently it is specified that in the event of bi-monthly publication of prices the frequency wi

PRIIPs

For PRIIPs that allow for investment in underlying instruments of a different nature, which are classified in different groups for risk calculation, how should the Summary Risk Indicator (SRI) be calc

PRIIPs

Does Point 53 of Annex VI apply inter alia to insurance-based investment products (unit-linked products as well as non-unit-linked products) in which the capital provided by investors is invested in U

PRIIPs

Could the ‘reasonable estimate of the consolidated price’ referred to in Point 17 of Annex VI be an average of observable quotes within a certain time frame?

PRIIPs

What is the meaning of the term “underlying investments” in Annex II, Part 1, Points 4-6 for a PRIIP that is an Undertaking for Collective Investment (UCI)? In particular, do we need to look at the po

PRIIPs

Point 80 of Annex VI specifies that “the costs are assessed on an ‘all taxes included’ basis. Which types of taxes are referred to in this point?

PRIIPs

Appendix I Standardised transaction costs: examples of calculation [Last update 4 July 2017] The procedure explained in Point (c) of Point 21 of Annex VI, Part I can be broken down as follows:

PRIIPs

Clarification is necessary on the specific currency risks which will be covered by Element C of Annex III of the Commission Delegated Regulation. Clarification is necessary for PRIIPs distributed simu

PRIIPs

Are PRIIPs with unconditional capital protection categorised as Category 2 or Category 3?

PRIIPs