September 14 2016
GBIC: Postpone the PRIIPs Regulation – threat of considerable legal uncertainty until all requirements are in place
The member associations of the German Banking Industry Committee (GBIC) warn of considerable legal uncertainty surrounding the planned introduction of standardised European key information documents for packaged retail and insurance-based investment products, or PRIIPs for short.
The European Parliament has today taken the unprecedented step of deciding to reject the so-called Level 2 measures of the PRIIPs Regulation. These measures were intended to standardise throughout Europe the content and presentation of the key information document required under the PRIIPs Regulation.
GBIC stresses that, without these Level 2 specifications which the European Parliament has rejected, banks have no legally binding basis for the design of key information documents. And the clock is ticking: the Regulation currently requires key information documents to be provided to consumers purchasing PRIIPs as of 31 December 2016. Examples of PRIIPs include closed and open investment funds, derivatives and other structured financial products.
The European Parliament’s decision means that, just over three months before the Regulation takes effect, there is no clear guidance on how key information documents should be designed. EU lawmakers should therefore postpone the date of application of the PRIIPs Regulation, stresses GBIC. On no account, in the view of German banks, can the Regulation become applicable from the end of 2016 as things stand.