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European Insurance and Occupational Pensions Authority

2532

Q&A

Question ID: 2532

Regulation Reference: (EU) 2017/653 - PRIIPs Delegated Regulation for key information document

Topic: Other

Status: Rejected

Date of submission: 22 Nov 2022

Question

After having studied the Questions and Answers (Q&A) document on the PRIIP Key Information Document (KID), we have doubts regarding the answer to question 9 found in the section "Performance scenarios (articles 3 and 8 and Annexes IV and V) [Last update November 14, 2022]”, page 34:

9. What is the calculation provided for the “linear transformation” in point 7(c)(iv) of Annex IV of the Delegated Regulation?
The linear transformation that must be carried out on the performance calculated for the sub-intervals indicated in point 7(b) of Annex IV of the Delegated Regulation (that is, shorter than the recommended maintenance period) is necessary for these performances to be comparable to those calculated for sub-intervals indicated in point 7(a) of Annex IV, (that is, with a duration equal to the recommended maintenance period), so that all of them can be classified later for the purpose of selecting the unfavorable scenario. The linear transformation means that the return over that shorter period (for example, a result of €8,000 over 2 years) is also considered the return over the recommended holding period (for example, a result of €8,000 over the holding period recommended).
In accordance with point 7(c)(iv) of Annex IV of the Delegated Regulation, we interpret that the "linear transformation" should have been applied to the returns and not calculated in monetary terms.

Of the following two possible options of the "linear transformation" that we consider, which is the correct one if we consider a single investment of 10,000 euros?

- Option 1: If the unfavorable scenario corresponds €8,000 for the 2-year sub-interval (i.e. yield_2 = LN(8,000/10,000) = -22.31%), then the unfavorable scenario for the recommended holding period (for example, 8 years) would be 10.000 * exp [yield_2* (8/2)] = €4,096 (IRR = -10.56%).

- Option 2: If the unfavorable scenario corresponds to a result of €8,000 over 2 years (IRR = -10.56%), then the unfavorable scenario for the recommended maintenance period (for example, 8 years) implies receiving €8,000 within 8 years (IRR = -2.75%).

EIOPA answer

This question has been rejected because the matter it refers to has been answered in Q&A, Section V, ‘Performance Scenarios’ question 9 of the PRIIPs Q&As.

Option 2 is the correct application.