In this response we reiterated our general concerns with the scope of the Key Information Document Regulation (e.g. inclusion of sophisticated investors) and described the specificities of private equity (in particular on cost disclosure)
In this response the PAE details the industry's concerns regarding the scope of the Key Information Document Regulation and the need to adapt it to sophisticated investors. It also highlights the irrelevance of existing performance scenarios for closed-ended and illiquid funds.
This PAE response comments on the proposed approach taken by the ESAs to determine the Single Risk Indicator and the costs contained in the Key Information Document ("KID"). It argues that the level of risk assigned to private equity is not based on actual data and that carried interest should not be considered as a cost due to its inherent characteristics.
The EVCA responded on behalf of the PAE to the ESAs Technical Discussion Paper on Risk, Performance Scenarios and Cost Disclosures set in the Key Information Document (KID) for Packaged Retail Insurance-based and Investment Products (PRIIPS). This consultation was launched to prepare the drafting of regulatory technical standards on the detail of the information to be contained in the KID, including calculation of costs and the definition of the risk indicator. The Standards will therefore have an impact on private equity funds when they wish to market to retail customers.
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