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    Luxembourg October 5th, 2017


    Some Practical Insights covered by RegTechs

    Click here to discover our last article


    Luxembourg June 6th, 2017


    PRIIPs: an innovative KID FACTORY capability thanks to an Exclusive Partnership

    See more


    Luxembourg November 10th, 2016


    PRIIPs delay until 1 January 2018 confirmed by the European Commission

    Following the rejection of the Regulatory Technical Standards (RTS) on the PRIIPs by the European Parliament in last September, the European Commission confirmed yesterday, 9th November 2016 a 12 month delay of the implementation of the regulation. Therefore, the new deadline is January 1st, 2018.

    This new deadline is valuable because it will give players the necessary time to agree on the expected revised Regulatory Technical Standards (RTS), the production of the Q&A and the implementation by the manufacturers.

    In addition, the delay will be in line with the implementation of MIFID 2 and Insurance Distribution Directive (IDD) which enables consistency implementation across the three regulations.

    Luxembourg September 30th, 2016

    TALEO Reporting – PRIIPS Quick fix – Some thoughts…


    In short, the PRIIPS RTS have been rejected due to the following supposed flaws:

    Credit risk for insurance-based investment products

    The credit risk can be fixed quickly because we can suppose that insurance companies can have a Credit Risk Measure of 1 or 2. Apparently and taken into account the states guarantees and Solvency II rules, a Credit Risk Measure of 1 seems to be an accurate indicator. However and if we take into account the maximum guaranteed by the states and the scope of the guarantee, a Credit Risk Measure of 2 seems more appropriate.


    Biometric risk premium and investment costs

    At least, the biometric risk premium and costs present problems due to the lack of common required holding period and range of ages of the subscribers. To overcome these difficulties, the RTS could drop this risk; alternatively allow either the use of narratives or the personalization of the PRIIP.


    Multiple Options Products

    Based on the fact that a PRIIP offering Multiple Options Products requires a generic KID and specific information of each investment option, we cannot see the added values of the proposed decomposition because, if we believe that we should apply the building block approach and value the whole PRIIP to capture all risk characteristics and performances. The new RTS should authorize explicitly the use of such approach.


    Exclusion of closed business product and annuities

    This approach could be a simplification to eliminate the workload of the players and to shorten the time to bring PRIIPS to market. However, the drawback will be the creation of a no man land for the existing clients with long term investments such as insurance-based products.  A pragmatic approach could be the exclusion of the existing business in short term and the coverage of all the sold products by January 1st, 2018.


    Performance scenarios and annualized cost

    The major the problem that exists with the current RTS is the use of the drift measured over the used historical period. The proposed use of the interest risk free rate of the required holding maturity could leads to misinterpretation and confusion. The quick fix will be the use of zero meaning no drift and all the performances figures will be function of the projected volatilities. The use of past performances is not an option because they cannot capture the likely future picture.


    More information coming soon …

    Luxembourg September 14st, 2016

    Today and requested last week by the ECON, The European Parliament rejected the final RTS by 602 against 4.  

    For the moment there is no indication on any likely delay. The consequences of this rejection are not yet known and we will keep you updated on any news.

    Luxembourg September 1st, 2016

    ECON (European Parliament Economic and Monetary Affairs Committee) has voted 55 / 0 against the PRIIPS RTS Level 2 (Regulatory Technical Standards) adopted and published on July 1st 2016.

    The vote has been motivated by the use of future performances instead of past performances, the treatment of Multi-Options Products and the legal uncertainty.

    PRIIPS level 1 still valid.

    Indeed PRIIPS performances scenarios in the current RTS could lead to positive performances even in the unfavorable scenarios. The opposite can happen is the favorable scenario. These situations reflect the observed average returns from the time series used for the computations.

    Multi-Options Products could lead to the production of high volume of KIDS and push the investors to confusion.

    Finally, computed indicators across different manufacturers of the same product could introduce legal uncertainty.

    TALEO Reporting believes that there is a real possibility that PRIIPS could still go live on January 1st, 2017. However, our company expects a delay of a minimum of 6 months because the redraft and agreement on new RTS cannot be easily reached in the coming months.