PIMFA’s response to DP22/6 suggested that the focus of the FCA’s review must be on the broader purpose of disclosure and on what it can realistically be expected to achieve. As well as responding to the FCA’s questions about specific disclosure features, PIMFA ‘s response called on the FCA, working with HM Treasury, to:

• reduce the weight placed upon disclosure as regulatory tool, recognising both low levels of consumer engagement and low levels of financial literacy/numeracy in the adult population;
• reduce the range of assets subject to any post-PRIIPs product regime by excluding assets such as retail bonds and convertibles and focussing on mass market products such as funds;
• take advised business out of the post-PRIIPs product regime, relying instead on the suitability letter to provide consumers with information that is tailored to their needs and circumstances;
• develop “headline” disclosures that are short and pithy, focussing on “The [X] things you need to know about this product before buying ….”;
• publish a coherent programme for reviewing retail disclosure across-the-board – not just PRIIPs but all rules requiring information to be provided to clients under MiFID, IDD, DMD etc.; and
• create a central Retail Disclosure sourcebook in the FCA Handbook, making it easier for firms to identify and comply with the wide range of rules relating to information provision.

The FCA is currently consulting on a replacement for PRIIPs.  Despite the calls made by PIMFA and other industry bodies, the proposal is for a highly prescriptive document containing much of the same information as the PRIIPs KID.  It has a slightly broader application than PRIIPs but does not cover the full range of retail investments.  Further information can be found via the links below.