JAC Response to the Discussion Paper on Key Information Documents for Packaged Retail and Insurance-based Investment Product (PRIIPs)

In November 2014, the three European Supervisory Authorities (ESAs) issued a discussion paper that set out their early thinking regarding the drafting of the Level 2 Regulatory Technical Standards (RTS) to support the EU PRIIPs Regulation (Regulation (EU) No 1286/2014). Past experience suggests that this will be an important opportunity to influence the outcome of this process. The Joint Association Committee has prepared a detailed response to the discussion paper. The JAC response covers areas of significant importance to the industry including issues such as the approaches to measuring and disclosing risk, costs and product performance in the KIID and the rules relating to review, revision and republication of the KIID. A further Discussion Paper on the more complex methodological aspects of the RTS is expected later this Spring followed by further Consultation Papers on the text of the draft RTS once this has been prepared by the ESAs.

Documents (1) for JAC Response to the Discussion Paper on Key Information Documents for Packaged Retail and Insurance-based Investment Product (PRIIPs)

ISDA Omnibus Canadian Representation Letter

On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...

Joint Response on Cross-margining

On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...