JAC has commented on the Commission’s proposal for a Regulation on key information documents (KID) for investment products, which forms part of the PRIPs Initiative. JAC warns that KID oversimplification could limit the usefulness of disclosure and mislead investors. It proposes amendments to the Level 1 provisions on the civil liability regime and on the relationship between the KID and the product terms and conditions. It also suggests that the Level 2 standards should discard including a synthetic risk/reward indicator, as it discourages investors from engaging with the full risk profile of the product.

(Source: JAC Comments on European Disclosure Rules for Retail Investment Products – 29 October 2012)