Silverfinch is building templates designed to aggregate and distribute data required by Packaged Retail Investment and Insurance Products (PRIIPs) regulation for Key Information Documents (KIDs) into its PRIIPs compliance engine. The company plans to finalise the solution following the release of Level 2 Regulatory Technical Standards (RTS) that could be published by the European Commission as soon as next month.
Initially slated for an end of 2016 effective date, PRIIPs was postponed in November 2016 until January 2018 – coinciding with Markets in Financial Instruments Directive II (MiFID II) – following the rejection of Level 2 RTS by the European Parliament in September. The rejection was based on the KID element of the regulation, which is designed to improve the quality of information provided to consumers.
Silverfinch is supporting PRIIPs KID compliance through the integration of two templates created by the PRIIPs European Working Group and recommended to the market by the European Fund and Asset Management Association. The European PRIIPs Template (EPT) is expected to be used by most asset managers and insurers to aggregate data that allows them to create a KID, while the Comfort European PRIIPs Template (CEPT) was initially designed for the German market, which requires more granular data, but may also be used in other jurisdictions.
Ashley Smith, senior vice president of business development at Silverfinch, says lessons have been learnt from Solvency II in the run up to PRIIPs, with templates defined in two months rather than the 18 months it took to develop the Tripartite Template for Solvency II. He comments: “The PRIIPs templates will take out a lot of pain experienced around Solvency II. We expect firms subject to the regulation to use the templates rather than develop bespoke solutions.”
The Silverfinch PRIIPs solution uses the same components as its Solvency II solution and is geared to the data collection, processing and calculation requirements of PRIIPS. The company does not produce KIDs, but is working with partners dedicated to KID document production, such as FundAssist and autoKIID, to complete this element of compliance.
Smith says there is variation in firms’ readiness for PRIIPs, with some firms working to cover all their funds and bring UCITS into the compliance frame, although UCITS are not required to be compliant until 2019, while others are only just beginning the journey.