Date: 26th February 2024

The Financial Services User Group (FSUG) welcomes the ongoing legislative and supervisory works aiming to improve the ‘Value for Money’ that retail investors obtain from their packaged retail and insurance-based investment products (PRIIPs). The FSUG argues that ensuring retail investment products are effectively designed to increase the financial wealth of investors should be amongst the primary obligations of product manufacturers, and it should be amongst supervisors’ core duties to ensure that investment products which consistently fail to fulfil this basic purpose are eliminated from the market. A truly consumer-centric approach to designing and supervising PRIIPs must start with acknowledging that their primary function is to increase the purchasing power of savings, that is, provide significantly positive real net returns to investors.