SIFA welcomes the opportunity to comment on the amendments of the PRIIPs KID. SIFA also appreciates the efforts the ESAs have made in order to make the PRIIPs KID more useful and understandable for the investors. However, given the scope of the amendments (only level 2) it is limited what the ESAs can amend. A full level 1 review is needed to fix the fatal flaws regarding for example performance scenarios and transaction costs.
Response to Joint Consultation Paper concerning amendments to the PRIIPs KID