- EFAMA and Better Finance released a joint-letter on packaged retail and insurance-based investment products
- They want the rules defining the detailed contents of the PRIIPs KID to be correctly calibrated
- They want to have the disclosure of past performance and transparency on fees
Better Finance and EFAMA have joined forces to call for investors’ concerns to be duly considered.
Both organisations have always been strong supporters of the “PRIIPs” Key Information Document (“KID”), seeing it as a powerful instrument for retail investors to enable sound investment choices by allowing easier comparisons within a wide range of investment products. In order for this to happen, the rules defining the detailed contents of the PRIIPs KID must be correctly calibrated so that investors are given meaningful, comprehensible and comparable information.
Unfortunately, the recently rejected draft RTSs on the PRIIPs KID suffer from a number of flaws, leading to clearly negative consequences for retail investors. Better Finance and EFAMA firmly believe these flaws need to be addressed if the RTS are to succeed in providing the right information to retail investors.
While Better Finance and EFAMA may have diverging views on other issues, those addressed in this letter are so crucial for individual investors as well as for asset managers that the two organisations have come to a consensual view here.
Peter de Proft, Director General of EFAMA, commented: “There are two crucial issues that need to be addressed: allowing the disclosure of past performance, and fixing the misleading disclosure of costs and fees, and in particular the calculation methodology of transaction costs. The joint letter explains why both topics need to be solved”.
Guillaume Prache, Director General of Better Finance, commented: “Past performances of an investment product are an extremely valuable piece of factual information for investors in their investment decision, if only for investors to know whether the product has made any money or not. It is very difficult to understand why investors should be deprived of such information”.
Both organisations call on the EU institutions to reflect on and address these two concerns in light of the fact that both are of utmost importance for retail investors, the very investors the PRIIPs Regulation is meant to protect.