EU Financial Regulatory Q&A Database

When several versions of a benchmark are available which differ in the approach taken to reinvestment of revenues, which version should be used in the past performance chart?

PRIIPs

Prior to 1 January 2023 is it possible to prepare a KID based on the new requirements in Commission Delegated Regulation (EU) 2021/2268, for example for a product launched between September and Decemb

PRIIPs

Do the rules concerning the UCITS key investor information document (KIID) still apply?

PRIIPs

What should be displayed in the bar chart for years when there is no data?

PRIIPs

Does the requirements in Articles 6(1) and 9 of the PRIIPs Regulation mean that past performance disclosed regarding a benchmark index should be consistent with past performance disclosure in other in

PRIIPs

Where a UCITS, AIF or unit-linked insurance-based investment product refers to an index in its investment objectives and policy as a benchmark and will measure the performance against that index, but

PRIIPs

Point 52(h) of Annex VI indicates that transaction costs are included in the ‘other ongoing costs’. What does this mean in terms of where transaction costs should be included in table 2 ‘Composition o

PRIIPs

The UCITS KIID framework introduced the concept of “Absolute Return Funds”. For these types of funds, there is no need to select an appropriate risk benchmark and the UCITS SRRI is determined in its e

PRIIPs

If a UCITS, AIF or unit-linked insurance-based investment product does not yet have past performance data for one complete calendar year (and is not a UCITS or AIF which may provide simulated data for

PRIIPs

Is it required to keep the same benchmark for the SRI and performance scenario calculations?

PRIIPs

Point 12 of Annex IV of the Delegated Regulation notes that where the objectives of the PRIIP make reference to a benchmark, that benchmark shall be used for the performance scenario calculations. How

PRIIPs

What is the intended calculation for the “linear transformation” in point 7(c)(iv) iof Annex IV of the Delegated Regulation?

PRIIPs

Could you clarify for which intermediate holding periods should we show performance scenarios during the lifetime of a product? (E.g.: 1.1 years product, with remaining lifetime of 9 months). We belie

PRIIPs

In terms of the identification of sub intervals in point 7(a) of Annex IV of the Delegated Regulation are these all contained within in the time period defined in point 6 of Annex IV?

PRIIPs

For the identification of additional shorter sub intervals in point 7(b) of Annex IV of the Delegated Regulation, does this mean only the sub intervals that are truncated by the end of the time period

PRIIPs

What approach should be taken for Category 2 PRIIPs for which there is not an appropriate benchmark or proxy with sufficient historical data which meets the criteria set out in point 5 of Annex IV of

PRIIPs

If the benchmark is changed, how should the chart of past performance be displayed for the period preceding the change?

PRIIPs

What is the relationship between point 11 of Annex IV and Article 15 of the Delegated Regulation?

PRIIPs

Article 14(e) of the Delegated Regulation refers only to the publication of past performance of the underlying Category 2 investment options as required by Article 8(3) and not to the requirement in A

PRIIPs

Regarding Article 8(3) of the Delegated Regulation: a) What is meant by "performance scenario calculations"? Is it necessary for the full calculations underlying each scenario to be published or just

PRIIPs

Point 15 of Annex IV of the Delegated Regulation states that for Category 2 PRIIPs for which there is not an appropriate benchmark with sufficient history, performance scenarios shall be calculated in

PRIIPs

Regarding the methodologies for performance scenario described in Annex IV of the Delegated Regulation ((EU) 2021/2268) it is not clear what approach should be used to build performance scenarios for

PRIIPs

Annex II, paragraph 10 of the Delegated Regulation shows sub intervals to use for funds with pricing frequencies of daily, weekly or monthly, but not what to apply for those funds with other pricing f

PRIIPs

If the PRIIP is an AIF investing into linear products yet the leverage on investments changes throughout time (therefore leverage factor is non-constant but underlying exposures are linear), would thi

PRIIPs

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?

PRIIPs

How does Article 15(2)(c) of the Delegated Regulation regarding the review of the KID apply to the different holding periods shown? If the mean return for the PRIIP's moderate performance scenario, ex

PRIIPs

The exchange as manufacturer may not know all the costs, since some costs are added by the broker. In this situation is it acceptable for the exchange only to report the costs which relate to the prod

PRIIPs

In the case of subscription products, should manufacturer also modify the entry costs, if the market conditions during the offering period increase the initial fair value and thus the entry costs are

PRIIPs

In the case of subscription products, shall the manufacturer modify the cost figures each time the KID is revised even if the revision is caused by a change in another element and his percentage varia

PRIIPs

What aspects should be considered by the manufacturer when determining the RHP of a PRIIP? In accordance with Article 8(3)(g)(ii) of the Regulation and Articles 2(5) and 6 of the Delegated Regulation,

PRIIPs

Does the KID need to be published on the public section of a website?

PRIIPs

The Delegated Regulation uses terms “biometric risk premium” and “insurance premium”. Do these terms have the same meaning?

PRIIPs

How should credit-linked notes be treated, for example which is their product category for the purposes of the MRM calculation?

PRIIPs

Is a KID always required when an investment product is listed on a regulated market?

PRIIPs

How does the information on the underlying options of a MOP need to be provided?

PRIIPs

Regarding the correction for risk neutrality in Annex II, 22(c) of the Delegated Regulation - each of the 10,000 simulated returns needs a correction to ensure that the simulated average return is equ

PRIIPs

When performance fees or exit costs are not applicable for a product - does the format of Table 2 Composition of costs allow that the manufacturer to mention ‘n.a.’ instead of ‘0%’ in the table?

PRIIPs

Does the categorisation of a retail investor depend on the definition in Directive 2014/65/EU?

PRIIPs

What is meant by factors not observed in the market as stated in Annex II, Part 1, Point 7?

PRIIPs

Can an appropriate benchmark or proxy continue to be used once sufficient data becomes available?

PRIIPs

How should the CRM be calculated when the credit risk needs to be assessed only for a part of the assets of the PRIIP? For example if there are both individual investment holdings representing 10% or

PRIIPs

Does “as appropriate” in Point 7 of Annex III mean that the wording of the elements A-J can be amended? Or should the manufacturer remove an entire text element if it is not suitable for a specific PR

PRIIPs

Can a credit assessment assigned to a group be used for the assessment of the credit risk of the relevant obligor?

PRIIPs

In accordance with Annex II, Part 2, Point 42 the credit quality step shall be adjusted to the maturity or recommended holding period of the PRIIP. Should the maturity to be used for this adjustment b

PRIIPs

Should the 10% threshold for calculating credit risk in Annex II, part 2, Point 35 be applied per instrument or per exposure?

PRIIPs

What are the implications of Point 53 of Annex II, Part 3 in terms of the monitoring of data? In particular, is it necessary to calculate the MRM on a daily basis?

PRIIPs

Which annual cost impact is shown in table 2 (composition of costs)? For insurance-based investment products, the table shows the impact of the different types of costs on the investment return the in

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

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

PRIIPs

Can non-ETDs use the same treatment as ETDs?

PRIIPs