EUSIPA has today filed a reply to the ESA’s Joint Consultation paper on selected PRIIPs provisions. In its response EUSIPA in particular rejects the proposal of integrating simulated past performance for structured products into the PRIIPs Key Information Document (KID).
Before changes to current methodologies are being made, EUSIPA pleads to arrange for an in-depth review of the existing PRIIPs implementing provisions. Such review needs to include an extensive testing of change propositions across all asset classes covered by the EU PRIIPs Regulation in the various national markets of the EU.
More details can be taken from the full document, which can be downloaded under the following.