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European Insurance and Occupational Pensions Authority
 

3052

Q&A

Question ID: 3052

Regulation Reference: (EU) 2019/1238 - Pan-European Personal Pension Product (PEPP)

Topic: General provisions (Art. 1 – 4 and 71 - 74 PEPP)

Article: 2

Status: Under Review

Date of submission: 22 Mar 2024

Question

According to Article 2 (15) of the PEPP Regulation an investment firm which manufacture PEPP products are allowed to distribute PEPP products it manufactures. We assume this includes distribution by tied agents of an investment firm whether in Home Member state or in Host Member state and such distribution is for the purpose of this question not considered 3rd party distribution. As per the PEPP Regulation Article 2 (16), 3rd party distributor can be: (i) financial undertaking as referred to in Article 6(1) authorised to distribute PEPPs not manufactured by it, (ii) an investment firm providing investment advice, or (iii) an insurance intermediary as defined in point (3) of Article 2(1) of IDD Directive. This definition does not include other persons, not governed by Union law, such as firms operating under Art. 3 MiFID II exemption regime. Is there possibility for a MS to include domestically other persons as PEPP distributors if they are, under national law, allowed to distribute financial products similar to PEPP?