The Association of the Luxembourg Fund Industry supports the promotion of a sound and transparent Responsible Investment market (or Sustainable and Responsible Investment - SRI).
ALFI however believes that the proposal should remain within the scope of advising on the procedures to be used to determine when a PRIIP KID can refer to specific environmental or social objectives:
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the advice should not add disclosure requirements;
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the advice should not amend the scope of MiFID II or IDD;
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the advice should not add to product rules; and
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the advice should suggest procedures, not exclude certain strategies.
The SRI market has already a variety of acronyms. ALFI recommends not to promote the raise of a new “EOS PRIIPs” acronym, which we believe would contribute to making the market more difficult to assess for investors.
A grandfathering clause should be foreseen: existing funds should be given time to comply if they elect to indicate this in their KIDs.
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© ALFI - Association of the Luxembourg Fund Industry
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