EU Financial Regulatory Q&A Database

In the case of actively managed funds (meaning there is not a benchmark that can reflect the performance) that have been valued on a weekly basis for more than 10 years (i.e. that currently have only

PRIIPs

In assessing whether the use of a particular benchmark or proxy is appropriate, potential assets in which the PRIIP invests, consistent with the investment policy, must be taken into account (point 16

PRIIPs

According to point 16 (a) of Annex IV, the assessment of the appropriateness of a benchmark or proxy depends, inter alia, on the risk-return profile where the benchmark or proxy and the PRIIP fall int

PRIIPs

Point 11 of Annex II, Methodology for the presentation of risk, defines the return over each period as the natural logarithm of the ratio of the price at the market close at the end of the current per

PRIIPs

The main difference between Category 2 and Category 3 is, in accordance with Annex II Part 1 Point 5, whether the condition of "constant multiple" is fulfilled. In the event where a UCITs product has:

PRIIPs

According to the PRIIPs Delegated Regulation, if the MRM class changes to a different MRM class, the PRIIP manufacturer shall attribute the corresponding MRM class to the MRM class which the PRIIP has

PRIIPs

Point 26 of Annex IV reads: ‘For Category 3 PRIIPs, the following adjustments shall be made for the calculation of the stress scenario compared to the calculation for Category 2 PRIIPs: (a) infer the

PRIIPs

5. Should entry costs be included in the 10 000 EUR amount referred to point 90 of Annex VI of the PRIIPs Delegated Regulation?

PRIIPs

What is the meaning of ‘1 year’ and ‘> 1 year’ in the table in paragraph 18 of Annex IV of PRIIPs L2? Specifically, we wonder whether ‘1 year’ encompasses all Recommended Holding Periods (RHPs) under

PRIIPs

Point 35 of the Annex IV on Performance Scenarios states that ‘the values to be shown for the intermediate periods for the unfavourable, moderate and favourable scenarios shall be calculated in accord

PRIIPs

Do FX forwards fall within the scope of the PRIIPs Regulation?

PRIIPs

Please clarify the term "PRIIPs open to subscription"?

PRIIPs

Taking into account Article 23(3) of Commission Regulation (EU) No. 583/2010, should the information on past performance in accordance with Article 8(3), first subparagraph of the PRIIPs Delegated Reg

PRIIPs

What is the difference between a "benchmark" and a "proxy" within the meaning of the Delegated Regulation? If an AIF does not have a sufficient historical price time-series and the PRIIP manufacturer

PRIIPs

Should a KID disclose cost information and scenario information about 1 year and half the RHP in case the investors may not be allowed to exit a PRIIP before the end of the RHP?

PRIIPs

Could an artificially created “synthetic” proxy be considered an appropriate proxy in accordance with the PRIIPs RTS Annex II and Annex IV?

PRIIPs

When sufficient history for the SRI calculation is not available to cover 5 years of data for a daily share class, can the PRIIP manufacturer decide to use a benchmark/proxy to cover up to 5 years of

PRIIPs

Should the costs disclosed in table 1 (cost over time) and table 2 (total cost) be aligned for year 1?

PRIIPs

Is currency risk described by Risk Element C applicable to investment funds, or should currency risk generally be considered by wrapper products / multi-option products only? In case currency risk is

PRIIPs

Does point 5(b) of Article 2 of the RTS – ‘an indication of whether the PRIIP manufacturer is entitled to terminate the PRIIP unilaterally’ concern i) market circumstances or ii) client specific circu

PRIIPs

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

PRIIPs

Could you confirm if products with recurring premiums are to be modelled as Category 2 PRIIPs or Category 3 PRIIPs?

PRIIPs

If a product, linked to a single ISIN code, is available in both the single and recurring premium versions, it is possible to provide a representation of the riskier version of the two by reporting in

PRIIPs

Could you confirm that for what concerns the calculation of performance scenarios, as specified in Annex IV, point 7, the manufacturer must always use monthly data even if the NAV is available at high

PRIIPs

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

PRIIPs

Could you confirm if manufacturers of insurance-based investment products are allowed to signpost to KIDs produced by fund managers instead of proper SIDs in their IBIP MOPs? What happens when the RHP

PRIIPs

In the case of an investment fund (UCITS or AIF), can the manufacturer of the PRIP be an entity to which collective portfolio management functions, or other functions, have been delegated to by the fu

PRIIPs

In life annuities, should the sum of rents paid up to the period be considered in the minimum scenario?

PRIIPs

2 And further detailed in particular in the Commission Regulation (EU) 583/2010 and corresponding ESMA Q&As 4. While currently UCITS (or their management companies) send their KIID to the home compet

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

How should actively-managed UCITS ETF be identified in the KID, and what information should be included in the “What is this product?” section of the KID? An actively-managed UCITS ETF should inform i

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

Can a fund with multiple share classes use the price history of an existing share class when a new share class is created rather than use the price history of a benchmark?

PRIIPs

How should UCITS ETFs be identified in the KID, and what information should be included in the “What is this product?” section of the KID? A UCITS ETF should use the term ‘UCITS ETF’ which identifies

PRIIPs

It should be clarified in Annex I of the Delegated Regulation, where the name of the group should be included and whether it should be shown in bold.

PRIIPs

What type of information should be included in the “What is this product?” section of the KID of index-tracking UCITS and index-tracking leveraged UCITS? For index-tracking UCITS, the following inform

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

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

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

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

PRIIPs

Is it possible to show the complete name of the PRIIP when first mentioned in the KID and then simply refer to it as “the product” or “the Fund” thereafter?

PRIIPs

Are the redemption prices of open-ended real estate AIFs "prices" within the meaning of point 5 of Annex II of the Delegated Regulation?

PRIIPs

What is the meaning of indicating ‘the degree of freedom from the benchmark’ in Article 2a(d) of the Delegated Regulation?

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

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

What is the meaning of ‘whether this approach includes or implies a reference to a benchmark’ in Article 2a(d) of the Delegated Regulation? A UCITS or AIF managed in reference to a benchmark index is

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

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