Date: 27th November 2018

BETTER FINANCE welcomes and appreciates the effort of the European Commission and of the European Supervisory Authorities to put forward proposals for targeted amendments of the Delegated Regulation (DR) concerning the presentation and content of the key information document (KID) for Packaged Retail and Insurance-Based Investment Products (PRIIPs).

First, BETTER FINANCE finds that the very short consultation timeframe (less than a month) on such an important as well as technical issue puts representatives of savers and consumers at a strong disadvantage and gives us too little time to provide a detailed and complete response.

Second, BETTER FINANCE wishes to stress that it has always strongly supported the aim of the PRIIPs Regulation:

  • It is the first – and so far the only - “horizontal” EU set of investor protection rules that encompasses both non-insurance based and insurance based retail investment products.
  • The PRIIPs KID aims “to enable retail investors to understand and compare the key features and risks of the PRIIP” (article 1 of the PRIIPs Level I Regulation). This major investor protection initiative must be effective and preserved for EU savers' sake.