PROJECT SUMMARY

PRIIPS RTS IMPLEMENTATION – 1 January 2023

Largest Belgian Asset Manager with EU branches and cross-border distribution

Take over the epic owner role and ensure the timely delivery of the project.

PRIIPs stands for Packaged Retail and Insurance-based Investment Products, which are investment products that retail investors can buy. The PRIIPs Regulation is a European Union regulation that aims to provide retail investors with clear and comparable information about these products through a Key Information Document (KID). The PRIIPs RTS are the Regulatory Technical Standards that specify the content and presentation of the KID.

The Commission Delegated Regulation (EU) 2021/2268 introduced changes to the way costs, charges and performance scenarios are calculated and displayed, as well as introducing template amendments. Also the obligation to provide past performance information (for non-structured products) and previous performance scenarios calculations on top of the KID itself was introduced.

All active funds with a UCITS KIID (end of UCITS exemption) and insurance products, distributed to retail clients, were impacted.

Challenge

  • Understanding and applying the complex and technical methodologies for calculating and presenting the information required by the RTS
  • Adapting templates, systems, processes and standard operating procedures to the changes introduced by the RTS amendments
  • Ensuring the accuracy, consistency and reliability of the data used for the calculations and disclosures
  • Providing guidance and support to the product manufacturers and distributors on how to understand and use the KID information effectively
  • Communicating and explaining the KID information to retail investors in a clear and understandable way
  • Complying with the deadlines and reporting obligations set by the PRIIPs Regulation, while managing time/capacity constraints, due to other regulatory projects impacting fund reporting with the same timing
  • Coordinating and communicating with multiple stakeholders across different jurisdictions and with interdependent projects

Approach

  • The project was structured with following tracks: Reporting, Risk, Pricing/Costs, Legal/Compliance and Communication Material (also Process Management and Product Development were involved)
  • Intensive alignment and follow up with project tracks and various stakeholders, during regular and ad hoc meetings
  • The project tracks were represented in a steering committee, which gathered on a bi-weekly basis
  • Planning and follow up of all necessary activities to prepare KIDs, past performance documents (for non-structured products), previous performance calculations files, to apply changes to prospectuses, annual reports, website pages, product pages and repositories, to embed the new KID in the purchase processes at the distributors, to notify to the regulators and to perform go-live client communication
  • In order to have sufficient time to dry run and prepare the production documents, a freeze period was agreed upon
  • Update/creation of standard operating procedures and processes
  • Project closing based upon a Project End Report, approved by the executive committee

Impact

  • Successful go-live on 1 January 2023: complete and timely publication
  • Limited number of aftercare issues
  • Proper handover

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