The regulator launched the appeal, which will also examine the related PRIIPs Regulatory Technical Standards, this week and seeks the profession’s view on the effect of the legislation, since it took effect in January.
The PRIIPs legislation requires those who produce, advise on or sell PRIIPs to retail investors in the European Economic Area to prepare and provide investors with standardised key information documents.
It legislation aims to improve consumer understanding and outcomes by standardising the disclosures retail investors receive, giving them the ability to compare competing products.
The FCA said it would like to hear from those who are “producing, advising on, or distributing PRIIPs (and preparing and providing KIDs), and from consumers now using KIDs to decide whether to invest in these investment products.”
The regulator admitted it was “aware there is some industry uncertainty about the scope of the PRIIPs Regulation – in particular, whether certain products are in or out of scope” and invited submissions on this.
The FCA added: “We also understand that there are concerns about the practical aspects of certain cost and risk disclosure requirements in the PRIIPs legislation, and in the resulting KIDs.
“In Chapter 3, we remind firms of what is required under the legislation, and invite input from firms and consumers about their experiences of the required disclosures.
“We also invite input on any other practical experiences with the remaining elements of the PRIIPs legislation.”
The call for input applies to:
• consumers and their representative bodies
• those who manufacture PRIIPs and those who advise on or distribute PRIIPs, including but not limited to:
• issuers of securities that are classed as PRIIPs (including businesses that do not require Part 4A authorisation under FSMA)
• life companies
• discretionary investment management firms
• firms providing services in relation to insurance-based investments
• fund managers
• wealth managers
• stockbrokers and other firms that provide advice to retail clients on funds, structured products and derivatives
• financial advisers
• firms operating retail distribution platforms
The regulator says it aims to publish feedback statement on this call for input in “early 2019.”