Date: 1st October 2018

As representative of investors and financial services users, BETTER FINANCE has raised concerns regarding the PRIIPs KID legislative framework in terms of investor protection and in particular the fact that standardised, easily comparable and long-term past performance data (of both the product and its chosen benchmark) are eliminated under the PRIIPs delegated regulation. The elimination of standardised, easily comparable data on past performance is a regressive step for investors and will reverse some of the partial progress made on making the investment market more transparent and accountable.