Beside the content itself of the consideration of which bonds fall or not under the scope of the PRIIPs regulation, one can notice that in its new communication, the ESAs JC recommends the co-legislators to specify more precisely the scope of financial products impacted by PRIIPs and to focus on packaged or wrapped products rather than assets which are held directly, to avoid any legal uncertainty on this point.
The lack of clarity on the financial instruments in scope of PRIIPs was already submitted to the European Commission in a letter sent by the ESAs JC in July 2018.
We hope that this “booster shot” will convince the Commission taking care of the ESAs’ opinion that meet also the voice of the industry, at least on this specific argument, in the revision of the PRIIPs regulation we are all awaiting.
