What is the optimal way to produce KIIDs?
There is no standard answer to this question, as depending on your needs you may choose either an in-house or outsourced solution. Choosing between the two depends on many factors, including availability of internal resources, scalability needs and in-house technology expertise. So how can you, as a decision-maker in your organization, determine when you need an external service provider? There are a few key questions you should ask yourself, so we created a quick aid that will give you an answer in less than 1 minute.
KIID Decision Aid
Are you getting good value for money?
Time is a limited resource and you should allocate it carefully in order to achieve your overall business goals. Is producing KIIDs in-house helping you achieving these goals or is it a distraction? Let’s take a step back, do you know how many hours your company is dedicating to KIIDs? How many employees are dedicated to KIIDs? How many meetings with other teams? Try now to estimate how much all these hours are costing you. It’s easy: divide the average annual salary in your company by the number of working hours in a year (OECD average: 1,770). Now multiply that by the estimated hours dedicated to KIIDs. Any surprise? Don’t forget to round this number up for the time spent by senior management in KIID meetings.
Do you distribute funds cross-border?
Selling funds cross border is a game changer; with translated versions, the number of KIIDs and the complexity of the process grow exponentially. Complexity grows because for the same jurisdiction you may have to produce more than one language version (e.g. Swiss German, Swiss French, etc.). Complexity also grows because KIIDs must be filed with national regulators and each of them accepts them in a slightly different way. Finally, complexity grows because you have to manage the relationship with one or more translation agencies and integrate that into your internal KIID production process.
Are you losing sleep over regulatory risk?
Hefty financial penalties have been imposed by regulators to fund promoters in recent years so it is paramount to have robust compliance processes in place. With regards to KIIDs you need to ask yourself if you have a well documented methodology to calculate SRRI and OGC that complies with the ESMA guidelines. You also need to be able to effectively monitor these indicators over time to avoid ending in breach of the regulation. Finally, you need to consider how easy (or not) it would be to produce the evidence of the correctness of your calculations in the event of a customer complaint, especially when the KIID in question was produced several months ago.
Are you ready for PRIIPs?
The PRIIPs regulation enters into force on 31/12/2016 and for several retail products it will be necessary to produce a PRIIPs Key Information Document (KID). Retail AIFs are in scope for PRIIPs, while UCITS funds have been granted a three year exemption (pending a review by end 2018), which means that a PRIIPs KID will be required for UCITS funds by 31 December 2019, at the earliest. However, UCITS and other funds which are wrapped in insurance or other PRIIP types will be required to provide detailed information to the wrapper in order that they may produce a PRIIP. In the absence of the provision of this information, the fund promoter runs the risk that their fund may be excluded from such wrappers post 31 December 2016.
Now you’ve got the key elements to determine if you are better off by outsourcing the KIID production. Download our KIID decision aid and contact us if the arrows point to “Better to outsource”.
KIID Decision Aid