Insurance Europe welcomes the opportunity to respond to the European Supervisory Authorities’ (ESAs) Technical Discussion Paper on the packaged retail and insurance-based investment products (PRIIPs). Insurance Europe supports the objective of the Regulation to enhance retail investor protection and improve retail investor confidence in PRIIPs. Moreover, Insurance Europe agrees that improving the transparency of the products offered to retail investors will contribute to this aim.
Insurance Europe appreciates ESA’s work on development of the methodology that is suitable for all different PRIIPs and takes their specificities appropriately into account. However, the short consultation period, made it difficult to provide in-depth feedback on such important but challenging issues. Insurance Europe understands that the timeline is determined by the PRIIPs Regulation. However, it should be avoided that the time constrains and resulting short consultation periods will result in unsuitable or insufficiently thought through methodology for some PRIIPs.