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ARTICLE · 29 NOVEMBER 2017

Updated PRIIPs KID Q&A

Travers Smith LLP
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Secondly, Question 4 (on pg 25) gives, for the first time, an answer that the template wording in the KID can be amended where it is misleading and then specifies those changes for an OTC derivative.

United KingdomFinance and Banking

 On 20 November, the Joint Committee of the European Supervisory Authorities ("ESAs") published an updated set of Q&As in relation to the key information documents ("KIDs") to be provided in accordance with the EU packaged retail and insurance-based investment products regulation ("PRIIPs Regulation"). The Q&A supplements the PRIIPs Regulation and the related technical standards and cover a variety of issues.

There are a number of new questions, two of which are of particular interest.

  • Question 2 (on pg 4) deals specifically with the application of the requirement for a KID where an investment product is listed on a regulated market and helpfully concludes that this does not mean that KID is automatically required, provided that the firm has "defined the product" as being meant only for non-retail investors. No further details on what "defined the product" entails has been provided.

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