4.7.1 Overall structure of the cost tables and use of two tables (Table 1 and Table 2)

The vast majority of respondents did not agree with the preferred Option 3 that the ESAs presented in the consultation paper. The main arguments provided were that the revised second table would be too complex and contain too many different figures, and that there would no longer be a correspondence between the two cost tables (i.e. the retail investor would not be able to arrive at the total cost figure by adding up the breakdown of cost figures). It was also asserted that the proposed descriptions of costs in Table 2 would not work for certain types of PRIIPs, in particular insurance based investment products.

Most respondents favoured an approach based on the current tables in the PRIIPs Delegated Regulation or an option incorporating elements from Option 1 and Option 2 in the consultation paper. Several respondents, including some consumer associations preferred Option 4 on the basis that it is simpler.