One of the few positive things that can be said about PRIIPs KIDs is that, unlike UCITS KIIDs, they don’t all need to be updated during the same short window at the start of every year. So PRIIPs providers can stagger their workload throughout the year, carrying out their annual reviews after their funds’ accounting dates, possibly.
On the other hand, providers need to keep an eye on their review timetable to ensure no KIDs slip through the net without at least one formal review every year. If there is a material change to a Summary Risk Indicator (SRI), return scenario or cost, FE’s clients will automatically receive a prompt to review and update the KID, but providers’ product governance procedures need to ensure the KID is revised in the event of a change to the text, such as a fund’s objective, the target market or any other content on the document.
Even if no changes are needed, providers need to show that they have reviewed all their KIDs at least once a year. If nothing else, it’s worth changing the issue date, so clients know it is current.
As we have now entered the fourth quarter of 2018, providers who have not updated any of their KIDs since the beginning of the year should start thinking about gathering the data they need for their annual KID review. This is particularly important for any providers with both UCITS funds and PRIIPs who want to avoid the double-whammy of reviewing their PRIIPs KIDs at the same time as their annual UCITS KIID refresh in January/February next year.
A quick check of FE’s PRIIPs KIDs clients throws up the following statistics:
16% of PRIIPs KIDs have been republished during the first couple of weeks of Q4;
42% of KIDs were last republished in Q3;
33% of KIDs were last republished in Q2;
8% of KIDs were last republished in Q1;
Fewer than 1% of KIDs have not been updated since they were first published in December 2017.
So, we can confidently say that FE’s KID clients will not be forced to spend their Christmas and New Year period reviewing their PRIIPs KIDs unless there is a material change that is either within their control (the text) or results from a change to the numerical data, in which case we will send them a reminder.
Can all other providers predict a quiet PRIIPs Christmas?
For further information, contact us.
