After holding a number of meetings on the topic, AMAFI has finalised its response (AMAFI / 20-02) to the public consultation published in October 2019 by the European Supervisory Authorities (ESAs) on amendments to the PRIIPs framework.

In its response, AMAFI stresses the importance of maintaining probabilistic performance scenarios and thus of not using illustrative scenarios, which have major drawbacks for structured products. AMAFI also reiterates the need to present costs in a way that is as comprehensible as possible to retail investors and consistent with MiFID 2. With this in mind, it repeats its call to scrap the reduction in yield (RiY) indicator.

AMAFI is also calling for a more comprehensive revision that encompasses Level 1 in order to promote greater regulatory stability. For the same reason, it considers that all new obligations should come into application simultaneously instead of being phased in. And given the large number of existing key information documents (KIDs), which cannot all be updated at the same time, AMAFI wants to see a grandfather clause for structured products that are on the market before the future amendments come into application.