Ref.: Public consultation on the preliminary draft of the CMVM Regulation no.
9/2017 on PRIIPS

On behalf of Commerzbank Aktiengesellschaft (“Commerzbank”) and Citigroup Global Markets Deutschland AG (“CGMD”), with the support of the Euronext Lisbon and the European Structured Investment Products Association (“EUSIPA”), we would like to begin by thanking you for the opportunity to submit our remarks on the proposed CMVM Regulation no. 9/2017, on packaged retail and insurance-based investment products (“PRIIPS”), which was submitted to public consultation on 10 November 2017 (the“Portuguese PRIIPs Regulation Project”), and which (i) develops and operationalises Regulation (EU) 1286/2014 of the European Parliament and of the Council of 26 November 2014, on key information documents for PRIIPS (“EU PRIIPS Regulation”) and (ii) revokes CMVM Regulation 2/2012.
As a long-term and committed issuer of various financial instruments in Portugal, and with the benefit of the expertise and experience of the Euronext Lisbon and EUSIPA, we believe we are well placed to offer cogent views concerning the marketing of any such instruments in the Portuguese market.
In light of the above, we hereby submit our observations concerning the Portuguese PRIIPS Regulation Project: