PRIIPs & MiFID II: Challenges, Implementation & Outlook

Since January 2018, the complex PRIIPs and MiFID II regulations require the disclosure of additional product information by insurers, asset managers and distributors. As a leading full-service provider in the regulatory domain, we with our partner Donnelley Financial Solutions (DFS) have supported around 30 of the biggest asset managers and insurers from the United Kingdom, France, Germany, Austria and Luxembourg in the implementation of their PRIIPs and MiFID II projects.

One of the major challenges for these regulations has been the calculation of transaction costs, where the major difficulty has been the procurement of historical arrival prices for the last three years, particularly instruments not traded on listed markets. To help our clients meet the deadline and where arrival prices were not available, we have implemented the UCITS exemption methodology and as part of this approach we classified more than 3 million transactions. To transition into Full PRIIPs approach, we are working with several data vendors to retrieve arrival prices for trades in 2018 and onwards. In total, we have generated more than 12,000 EPTs and 24,000 CEPTs for our clients. In addition, we have generated more than 10,000 EMTs for asset managers. We also support other formats, such as WM Daten and OpenFunds.

As a full-service provider, we are responsible for the collection of EPT data for insurance companies, the calculation of PRIIP’s product data, the generation of product KIDs according to 10a and 10b and the linking of the assigned fund data via a flexible web service. Although many insurers are still using the UCITS KIIDs with estimated transaction costs, it is planned to replace this data with the generated PRIIPs EPTs in the coming months. For our customers in the insurance industry, we with our partner DFS have collected around 10,000 PRIIPs fund data (EPT) and generated around 40,000 product KIDs.