Regulatory Frequently AskedQuestions86

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    Risk is summarized with a Summary Risk Indicator (SRI) on a scale from 1 (lowest risk) to 7 (highest risk). This reflects both market risk (volatility of returns) and credit risk (issuer default risk).

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    Where the time series covers more than 10 years, the manufacturer may proceed directly to the volatility calculation. Where the time series covers less than 10 years, a simulation approach must be used, based on historical values of either a reference asset or an appropriate benchmark. In all cases, the time series must not end more than 60 days before the calculation date.

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    • Category I (PE/Real Estate): often quarterly NAVs, higher risk by default (SRI 6)
    • Category II (UCITS): straightforward volatility-based risk (VEV using Cornish Ficher formula)
    • Category III/IV (Structured Products): complex payoffs, simulation-based risk score.
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    • Stress: formula-based, using stressed volatility.
    • Unfavorable/Moderate/Favorable: sliding window method across historical data (can be a blend of actual PRIIP price data, reference share class and proxy/benchmark)
    • Unfavorable: article 7B shrinking window ensures conservative worst-case outcomes.For category III instruments, the scenarios are determined via a Monte Carlo simulation.
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    Costs are always based on: (1) a 10,000 notional investment, (2) 0% return assumption for 1 year holding period and based on moderate scenarios for the other holding periods. This ensures comparability across products.

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    Costs are shown in two tables: (1) Cost over time: expected costs at 1 year, halfway, and at the recommended holding period. (2) Composition of costs: breaking down one-off, ongoing, transaction costs and performance fees (based on a 10,000 investment).

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    Yes. The CCI regime applies to non-UK products if they are made available or marketed to UK retail investors. The jurisdiction of the product or issuer is not relevant; what matters is whether UK retail investors are being targeted.

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    Not necessarily. A score of 7 can indicate either that the product allows losses beyond your initial investment or that it exhibits extremely high volatility. Some funds, such as certain crypto funds, are classified as 7 due to their volatility, even when losses are limited to the initial investment amount.

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    UCITS have, usually, daily NAVs and linear payoffs (no embedded options/leverage). Therefore, they fall into Category II with simpler, volatility-based calculations.

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    No. Firms are not required to describe a target market. The FCA considers that the information included in the product summary provides consumers with sufficient information to assess whether a product is suitable for their needs.

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    Yes they are in scope of CCI. Just like CEIFs (listed Closed-Ended Investment Fund).

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    No. PRIIPs fall into four categories depending on NAV frequency, payoff structure and availability of (sufficient) historical data. Generally we could state that UCITS are always Category II, closed-ended privat market funds (Private Equity/Real Estate) are Category I, and Structured Products fall into Category III or IV. Semi-liquids (evergreens) are often Category I because of the lack of an appropriate benchmark or proxy.

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