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ARTICLE · 13 JULY 2016

PRIIPs And Grandfathering: Where's This Debate Headed?

KPMG Luxembourg
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With the PRIIPs Regulation's implementation date approaching—31 December 2016—there are still some questions unanswered for the insurance industry.

LuxembourgFinance and Banking
Geoffroy Gailly
Geoffroy Gailly
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With the PRIIPs Regulation's implementation date approaching—31 December 2016—there are still some questions unanswered for the insurance industry. Specifically, doubts have arisen regarding the existing portfolio of contracts that will be still in force on 1 January 2017. In this article, we will aim to shed some light on the debate surrounding this issue.

The main question posed by the market players affected by PRIIPs is very often linked to legacy: do manufacturers need to provide a KID to investors who signed contracts before 1 January 2017 that are still in force? Considering the pre-contractual nature of the KID, would it be reasonable to assume they do? Taking into account the considerable number of existing contracts held by many stakeholders (more than 20,000 in some cases), these seem to be very pertinent questions.

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