4.11 Feedback on other issues not discussed in the consultation paper
4.11.1 Introduction
Feedback was received on a wide range of different issues concerning both the PRIIPs Regulation and Delegated Regulation.
When considering these issues, given the timeline for finalising this review, it was necessary for the ESAs to prioritise those issues that were considered relevant and possible to address as part of this review, taking into account:
- The extent to which the feedback corresponded to information gathered by the ESAs and NCAs since 1 January 2018 that the current rules may not be achieving their intended outcomes in practice;
- The main aims of this review, including to address primarily issues concerning the Delegated Regulation;
- The feasibility of addressing the issue within the timeframe.
In particular, it can be mentioned that despite the numerous comments received on this topic, the ESAs judged that it was not appropriate to address issues of the scope of the PRIIPs Regulation during this review. This also took into account the general recommendation that the ESAs made on this topic already in a Supervisory Statement published in October last year [JC 2019 64].
4.11.2 Summary risk indicator