4.10.1 Proposed approach for the most commonly selected investment options

All respondents from the financial industry were critical of this proposal, which they argued would be costly to implement and would not bring benefits in terms of consumer understanding. Some of the challenges raised included:

- The approach is not meaningful in the case of products where the investment selection is left entirely to the retail investor;

- The proposal would introduce a new type of document in addition to the generic KID and specific information;

- The (four) options selected are likely to be taken as recommended options;

- It is not clear how to apply some aspects of the proposals in practice, such as how the most commonly selected options could at the same time reflect the diversity of investment objectives;

- It will increase the number of KID, and this was a particular concern where the PRIIP manufacturer had already decided to prepare several KIDs for the same product, such as reflecting different possible holding periods;

- In the absence of consumer testing it is not possible to know whether the proposals will be an improvement.

As noted by some respondents, the ESAs consider that the optimal way to address the challenges for MOPs is to use digital solutions. However, to require such an approach would necessitate changes to the PRIIPs Regulation (see Section 4.12 below "Digital solutions").