4.3.1 Introduction and summary of final proposals
This Section 4.3 discusses the feedback from the public consultation, the results of further extensive quantitative testing by the ESAs on a wide range of PRIIPs and the proposed way forward.
In summary:
- Respondents to the public consultation were opposed to the use of the core proposal in the consultation paper based on implied risk premia, namely dividend yield for equity products, (see Section 4.3.2);
- The quantitative testing by the ESAs indicated significant issues to apply this methodology to investment funds, (see Section 4.3.3);
- For non-structured investment funds and PRIIPs linked to these (e.g. unit-linked insurance-based investment products), based on the testing conducted, the ESAs are of the view that the most justified proposal from the perspective of its technical soundness and understandability for consumers is to use scenarios estimated more directly from the actual price history of the fund or a relevant benchmark
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