30.01.2014
Information for retail investors (PRIPs)

Trialogue start on the Regulation on key information documents for investment products

The European legislators have specified their negotiation framework for the trialogue on the Proposal for a Regulation on key information documents for investment products (PRIPs). The German insurance industry would like to take this opportunity to state its position regarding the trialogue. This is based on three fundamental considerations: Appropriate limitation of the scope, focus on pre-contractual product information and focus on key information in the key information document.

The attempt to introduce a uniform product information document for as many financial products as possible is detrimental to the comparability and comprehensibility. Short-term, speculative financial instruments used for the purpose of investment cannot be compared in a reasonable way with pension products with monthly premiums and lifelong, guaranteed annuity payments.

While the COM submitted a proposal which regulates the harmonisation of pre-contractual product information requirements, the EP extends the Regulation to a general, very restrictive financial market regulation. Already existing regulations (e.g. Solvency II Directive) as well as on-going reform processes (e.g. IMD2, MIFID2) were not taken into account in this context.

Key information documents should be concise to be read by customers. The proposal by the EP, however, contains a very extensive PRIPs KID with two clauses, 14 main topics and 29 subtopics, supplemented by an annex to be filled in by intermediaries (Article 8).

The GDV’s complete position paper is available in the download section.

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>> Position Paper on PRIPs-Regulation in German

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Position Paper

regarding the trialogue on the Regulation on key information documents for investment products (PRIPs)

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