Stellungnahmen

BdV largely agrees with EIOPA’s proposals on level 2 regulations for PEPP and gives further details on information duties (KID / PBS), comparability of cost indicators, cap of costs for Basic PEPP, linkage of accumulation and decumulation phases. etc.

We primarily comment on questions linked to insurance-based investment and pension products. As for former consultations on the PRIIPs KID we clearly stress our criticism of the Reduction in Yield as aggregrate cost indicator being mathematically correct, but not understandable for customers. We propose to replace it by the Reduction in Wealth.