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Where does the market stand on KIID? - 04/10/2012


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Following the success of the first Key Investor Information Document (KIID) survey, which assessed where the market stood in its preparations of producing the KIIDs, Deloitte Luxembourg has once again surveyed the market to ascertain how those plans and anticipations outlined, have panned out. The survey was sent to the majority of Luxembourg based management companies in early July to coincide with the KIID entering its mandatory phase.

The results of the survey offers insights into what aspects of the KIID the market has found the most challenging, both in subject matter and from an organisational point of view.

Over 70% of the respondents found their KIID project to have been more difficult than they had anticipated and, unsurprisingly perhaps, ‘plain language’ features high in the league tables, with over 60% of the market having categorised it as ‘challenging’.

In its analysis Deloitte draws these elements together to point towards conclusions that may indicate the way ahead as KIID continues to move from the status of a project to ‘business as usual’.

On the other hand, there are also some surprises. In general, the market reports that it has coped well with the challenge of the Synthetic Risk and Reward Indicator (SRRI).

The analysis of the survey challenges that conclusion and goes further than the first level of complexity to question if the full costs of the time of skilled risk specialists to this activity has been factored in to the equation. And cost overall is discussed at some length.

Finally the survey looks to put the KIID into its broader context, and discusses where the implications are for the current document, now that the first part of the Packaged Retail Investment Products Directive (the part concerning investor information) has been issued in draft form.

Lou Kiesch, partner at Deloitte Luxembourg, states: “We draw on our regulatory knowledge and practical market involvement to explore what the future for the KIID as we know it today may hold and what impact this first part of PRIPS may have on business in the market. Our survey has clearly answered some questions, however, it has also raised new ones. Above all, it offers insights that will allow direct comparison of individual experience with what has been going on across the wider spectrum. In any case, we can certainly say that we are far from finished with the KIID just yet.”

The full results of the survey are available on the Deloitte Luxembourg website: http://www.deloitte.com/lu/survey/kiid

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