EBA欧洲银行-BSG-response-to-Consultation-Paper-28EBA-JC-2015-73292029-January-2016_11页_284kb

报告摘要

EBA Banking Stakeholder Group Consultation Response on PRIIPS KIDs

Core Content

The EBA Banking Stakeholder Group (BSG) provided detailed comments on the Joint Consultation Paper JC/2015/073 regarding the Key Information Documents (KIDs) for Packaged Retail and Insurance-based Investment Products (PRIIPS). The group emphasized the importance of transparency and comparability in the information provided to retail investors, highlighting the need for clear, easy-to-understand disclosure practices.

Main Views and Key Information

General Comments

Transparency and Comparability: The BSG stressed that transparency in product information is crucial for retail investors, particularly for investment products that involve complex and uncertain factors.
Harmonized Templates: The aim of the PRIIPS Regulation to provide a harmonized template for KIDs is appreciated, as it enhances comparability and informed choice.
Complexity of Templates: The group acknowledged the challenge of developing such templates, especially for diverse investment and insurance products, and supported the ESAs in their efforts to improve disclosure standards.

Responses to Consultation Questions

Question	Key Points
Q1	The BSG welcomed further clarification of the criteria in Recital 18, as they are too general and may lead to inconsistent implementation across member states.
Q2	The use of a single default amount in EUR is preferred, with the option for member states to set additional amounts in their local currencies.
Q3	The BSG suggested that the methodology for category II products should not be overly complex, and that category III's bootstrapping approach could be simplified.
Q4	The BSG agreed with the proposed confidence interval for computing VaR.
Q5	The existence of a compensation or guarantee scheme should not be considered as a mitigating factor in credit risk assessment due to the diversity and complexity of such schemes.
Q6	The BSG opposed the voluntary increase of SRI, as it could complicate the comparability of similar PRIIPS.
Q7	A tenor adjustment for credit risk assessment is acceptable if it reflects market practice, but the BSG cautioned against unnecessary complexity.
Q8	The BSG questioned the relevance of the 5-year tenor criteria for MRM, suggesting that it may be arbitrary and misleading.
Q9	The BSG supported the automatic allocation to MRM class 1 for products with full capital protection, regardless of tenor.
Q10	The BSG noted that the credit risk assessment should not assume mitigation based on compensation or guarantee schemes due to their varying nature and limited coverage.
Q11	The look-through approach for credit risk assessment is challenging, especially for complex PRIIPS, and requires underlying manufacturers to provide relevant data.
Q12	Currency risk should be considered if it affects the guaranteed value of the PRIIP, and should be disclosed by the distributor outside the KID.
Q13	The BSG did not agree with duplicating early withdrawal information in the KID, as it may cause confusion.
Q14	The BSG supported using the performance fee as a basis for performance calculations and suggested that the same benchmark return should be used for all scenarios.
Q15	The BSG considered a graph-based presentation of performance scenarios as more effective than tables, but emphasized the need for clarity.
Q16	The BSG disagreed with including spread as a cost, as it is a risk mitigation measure, not a cost.
Q17	No comment was provided.
Q18	The BSG supported the use of annualized costs for better comparability, especially for long-term products.
Q19	The BSG supported the separation of investment costs and biometric risk premiums, as aggregating them would mislead investors.
Q20	The BSG suggested that the cost section should include both percentage and monetary values, aligned with MiFID 2.
Q21	The BSG preferred a graphical presentation of the breakout table for clarity, but noted that it may not offer significant advantages over tables.
Q22	The BSG supported including performance fees in the KID, as they are important for understanding the total cost structure.
Q23	The BSG recommended combining the first and second tables of Annex VII to reduce information overload, provided clarity is maintained.
Q24	The BSG agreed with the proposed method for cost-free scenarios, as it aligns with the intent of the regulation.
Q25	The BSG supported the detailed breakdown of costs, but cautioned that distribution costs should be excluded from the KID.
Q26	The BSG preferred expressing costs as a percentage of the initial invested amount for simplicity and clarity.
Q27	The BSG noted that the Impact Assessment is detailed but missed some important policy issues, such as the delivery method of KIDs and the scope of products requiring KIDs.

Conclusion

The BSG generally supports the aims of the PRIIPS Regulation to improve transparency and comparability for retail investors. However, they emphasized the need for clarity, consistency, and alignment with existing regulatory frameworks like MiFID 2. The group also called for more detailed guidance on the practical aspects of KID delivery and the scope of products subject to KID requirements.

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