EFAMA is adamant that the Covid-19 crisis makes it all the more important for action to be taken quickly on revisions to the PRIIPs KID, which it has long argued is “fundamentally flawed”. It says the current format gives investors misleading information and that giving them clear and relevant information, with a proper framework will both protect their interests and help them better participate in the economic recovery post-pandemic.
- comparability at any costs if not the right solution, because it is not possible to provide clear, fair and not misleading information in relation to widely differing products in one set form;
- past performance information is paramount; and
- performance scenarios should be looking at how a product will function in certain conditions, based on historical information.