Where do you see the biggest challenges of the new PRIIPs regime?
As I see it, there are two main challenges concerning PRIIPS. The first one relates to why the PRIIPS regulations was introduced. The initial intent was to increase transparency pertaining to costs, and comparability of products. While large amounts of information will be made available to the public, by means of these regulations, one could argue that the data is in itself very complex. Combining that with an increased level of product complexity, as is today the case, the transparency intended is not that easily achieved.
Secondly, it is important to consider that one can only reliably comply with the PRIIPS regulation over the long run, if this is based on a sound data management approach. While the challenge to collect all relevant data can seem insurmountable it should not be neglected that such data also has to be managed over time. Specifically in terms of:
- Who updates data when products change?
- Where does the data need to go once changed?
- Are processes in place to ensure visibility and distribution of updated data?
In consequence, where the challenge right now seems to concentrate on gathering data and ensuring that the new KID will comply with the regulation, the question of a more sustainable approach on how to manage that data is often forgotten.
In our recent poll the majority were concerned about the transaction and risk calculations, how does Seqvoia approach that concern?
I think it is very important to address such concerns immediately, because the new KID can easily create a lot of worries for something that while new within the KI(I)D space—is not that novel in other settings. That is essentially the philosophy we have taken to heart by developing an approach that leverages the best knowledge there is on the market. Thus, while we perform risk and performance calculations, using a fully integrated API with our partner, we do not offer PTC calculations ourselves as this is beyond our field of expertise. However, we work closely with our clients and their expert provider to ensure a smooth integration into their existing business processes. Consequently, we offer a full audit trail and controls that ensure data is consistent before going out into the market in whichever set-up chosen.
What are some of the areas that clients seem to be primarily worried about? What is Seqvoia doing to ensure that such worries and issues are addressed?
We really want to advise and support our clients and decided early on that the best way to do so was by means of workshops and webinars. These forums allow us to not only gauge potential concerns on the client-side but also to proactively address topics that we know will be on many minds. Such questions range from:
- How to simultaneously produce UCITS KIID and PRIIPS KID
- The project timelines and the design of adequate business processes supporting PRIIPS
- The ongoing consistency of disclosures across the business and a multitude of distribution channels.
Our PRIIPS analysis provides a complete overview of requirements, and we have more sessions coming up – so if you are interested, please reach out to be included.