PRIIPS notification

Peter Rice, Investment Proposition Manager

Thursday, 5th January 2023

PRIIPS notification

Some minor changes to Packaged Retail and Insurance-based Investment Products Regulation (PRIIPs) legislation came into force on 1st January 2023. Key changes from PRIIPs 1 to PRIIPs 2 include the following:

The Key Information Document (KID) will be updated monthly as opposed to yearly
A new page on irishlife.ie will store historical ‘performance scenarios’ from the KID documents and actual past performance of the fund
There is a new ‘minimum’ scenario introduced within the ‘performance scenario’ table

PRIIPs 2 applies to all investment and savings new business issued on or after 1st January 2023. There is no change to the current scope i.e. it does not apply to existing customers or policies, nor to top-ups or switches on existing policies.

The intention of the legislation remains unchanged - to standardise the way product charges, underlying risks and expected returns are presented to consumers, with all providers using the same methodology for the calculations and presenting results in the same format.

If you need further information, please contact your account manager

Frequently asked questions

Background

Is there any change to products included?
No - all wrapped and/or packaged plans and investment products sold to retail investors are covered by PRIIPS. For Irish Life, this covers lump sum investment bonds and regular savings products. All pensions, direct purchase of shares or bonds, bank accounts and products only available to professional investors (as defined by MiFID II) continue to be out of scope.

I don’t have the client’s email address. Is there any change to how I can send them the KID?
Under the legislation, the default option continues to be to provide the paper KID. If you don’t have the client’s email address, you should provide a paper KID.

How is this change helping the client?
The aim of the changes is to make the expected returns in the performance scenarios more accurate and to increase disclosure by providing more detailed explanations on the costs in the KID.

Do I need to give the new KID to all my clients?
No. The new KID only applies to investment bonds and regular savings products sold after 1st January 2023. It does not apply to existing clients or to new clients only taking out a pension product (including ARFs).

Key Information Document

Is there still a KID for each fund?
Yes. Irish Life will continue to produce a KID for each fund option currently available under each product. A KID will not be produced or available for funds that are closed or no longer available to new business.

Where can I find the new KID?
All KIDs will be in the same location on the Irish Life website - in the Irish Life Fund Centre under Investments. These KIDs will be available to the public and brokers. The KIDs will continue to be available on the MyBiz area of bline, as well as Portus. Brokers will only be able to access the KID for generic Irish Life products and their own specific products through bline and Portus.

Are there any changes to the storage of the KID on file?
No. The broker should continue to be able, if requested by the Central Bank, to demonstrate that they have complied with their obligation under the PRIIPS regulations and provided the relevant KID to the customer in the appropriate format. Keeping a copy of the KID on file may help in this regard.

How often is the KID updated?
Under PRIIPs 1, the KID must be produced at least once a year and/or if there are any material updates required to the KID in the meantime.
Under PRIIPs 2, the KID will be updated monthly. The legislation requires the monthly calculation and publication of performance scenarios. Irish Life has made the decision to reproduce the full KIDs monthly. The costs within the KID continue to be updated quarterly and this will be visible by the ‘cost effective date’ on the front page of the KID.

Costs and charges

Does PRIIPs 2 change how costs are disclosed?
All contractual product charges are unchanged. How we disclose fund transaction costs on the KID may change/increase in a minority of cases due to negative transaction costs not permitted under PRIIPs 2.

What are negative transaction costs?
Negative transaction costs are no longer permitted to be disclosed under PRIIPs 2. Negative transaction costs can be considered as a gain not a cost, and they arise when the market moves in such a way that the timing and, therefore, the price units are bought or sold at are a gain to the fund.

Are there any terminology changes in the cost tables?
Yes, the reduction in yield has been renamed the ‘annual cost impact’. This is designed to make the KID more customer friendly.

Risks

Are there any changes to the risk rating used for PRIIPs?
No, except for guaranteed funds with a price pledge, i.e. PCMF and Amundi Protect 90. Previously, these were calculated on the KID as Summary Risk Indicator 3. In PRIIPs 2, the calculations have changed for these types of funds and will result in a Summary Risk Indicator of 2. This is more in line with Irish Life risk ratings.

Expected returns

Are there any new performance scenarios in the KID?
Yes, where applicable, the ‘minimum scenario’ values will now be included in the performance scenario table. This scenario applies for price pledged funds. For all other funds a line will be inserted stating there is no minimum return.

Are there changes to how the expected returns and performance scenarios are calculated?
Yes, for the favourable, unfavourable, and moderate scenarios. Previously the expected future returns were modelled based on actual performance data for the last 5 years for each fund. The performance data was used and adjusted to create expected future returns for the periods shown in the KID. The projected figures shown on the KID changed from year to year as actual historic returns changed.
Under PRIIPs 2 the expected future returns are based on actual performance of the fund over a period equal to the fund’s recommended holding period + 5 years. For the majority of Irish Life funds, this is 12 years. For some cash funds with a 5-year recommended holding period this is 10 years. This performance data is used without adjustment to create expected returns in the performance scenario table.
The expected return methodology for the stress scenario remains unchanged. This scenario was tested by the regulators using performance data from 2020 during Covid and was found to be fit for purpose.

Are the performance scenario changes evident in the KID?
Yes, it is obvious in the performance scenario table. Under PRIIPs 2, there is a requirement to disclose the period over which the return was achieved. For example, if the recommended holding period is 7 years and the favourable return was achieved over the period 2014 to 2021, this will be disclosed on the KID.
There will be separate disclosures for each holding period and each of the unfavourable, moderate, and favourable scenarios.
There is also a statement on how many years performance data is used in the performance scenario calculations.

What happens if the fund launched less than 12 or 10 years ago? There won’t be performance data back that far?
Under the PRIIPs regulations, Irish Life is required to backfill the performance data using suitable benchmarks or proxies. There are strict rules governing the decisions providers are required to make to backfill the price data.

Will the figures within the performance scenario table change regularly?
Yes, for the favourable, unfavourable, and moderate scenarios however it will depend on how the market performs. Under PRIIPs 2, the 12 years past performance data is on a rolling basis so the data inputs will change regularly. The figures within the performance scenario table are based on actual past performance and therefore changes to these figures are dependent on how the market performs month to month.
The stress scenario will continue as is for funds with no minimum return. For funds with a minimum return, the minimum performance scenario depends only on costs and guaranteed percent and will be equal to the stress scenario.

What’s with the stress scenario for cash funds? Why is it higher than the favourable scenario?
PRIIPs 2 rules have solved this potential outcome that could occur in PRIIPs 1 – the stress scenario can now no longer be greater than the unfavourable scenario.

Other

Will the ready reckoner be updated?
Yes, the ready reckoner will be updated per PRIIPs 2 terminology changes as described, the performance scenarios are updated and the intermediary holding period has been removed. The new ready reckoner will be available from 1st January 2023.

Is the Irish Life application form changing?
No, there are no changes. Confirmation is still required from both the broker and the customer that they have given and received the KID in accordance with the regulations.

Is anything else changing?
There will be no performance scenarios or costs shown at the intermediary holding period in the new KIDs. For funds with a recommended holding period of 7 years, the intermediary period was 4 years. Following customer research, it was decided showing values at year 4 was of no benefit to the customer.
There is a new webpage showing previous performance scenarios for each product/fund from January 2023, accumulating each month. A bar chart will displays the actual performance of the fund. A link to this new webpage will be available at the bottom of each KID in the ‘other relevant information’ section.