Although there is no regulatory obligation for non-MiFID firms and fund manufacturers to complete European MiFID Templates (EMT) and European PRIIPs Templates (EPT), as an Asset Manager there are a few things you should consider before deciding not to provide these to your distribution network.
● EMT and EPT provide your distributors with the specific data they need to ensure they are compliant
● Responsibility to be compliant with MiFID II lies with the entity authorised to distribute investment products, which could be the manufacturer or appointed third party distributor.
● A product manufacturer may not necessarily be subject to MIFID II or PRIIPS regulation, however if they do not provide compliant information neither a direct salesforce nor third party distribution partners will be able to sell their investment fund products.
● Without MiFID and PRIIPs data available to share, there will be no distribution channels to promote and sell investment products, and distributors may de-select them from their product offerings.
Dissemination is often underestimated in terms of complexity regarding the recipient’s requirements. EMT and EPT provide standards about content, structure and format of data only, while output format and transmission methods can vary quite a lot;
● Outputs may be formats:
○ XLS, CSV, txt, XML, Openfunds, FundsXML
○ One output per ISIN
○ Multiple ISIN in the same output
● Dissemination frequency:
○ Recurring (i.e. Daily, weekly, monthly)
○ Ad-hoc, based on material changes
● Dissemination methods include:
○ external sFTP
○ custom API, defined by the destination to receive data (i.e. SIX, WM Daten)
The process of sharing EMT and EPT to your distribution network can be onerous, however dissemination of this data does not have to be this complex, in fact, it can be extremely easy, simple and fast.
How we can help
At KNEIP we have developed an online digital platform that not only allows for the production of KID, EPT and EMT for clients, but also the dissemination of these documents and data templates to their distribution network.
In short our platform:
● Integrates one set of data and produces a variety of outputs, including KID, EMT, EPT and CEPT
● Adapts to the different formats and transfer requirements amongst different distributors
● Keeps track of what has been sent, when and to whom
● Links production and dissemination by putting rules in place, that if triggered by i.e. a risk change, will automatically send the required outputs
● Focuses on the scope of products which the distributor is allowed to sell, and therefore the distributor will only receive the relevant share class data
● Allows you to publish and market your funds data on electronic platforms, e.g. Bloomberg and Thomson Reuters, and reach your insurance distributors directly
● Receives target market data (both positive and negative) from the distribution network, giving a manufacturer complete oversight of their distribution network.
Under MiFID II & PRIIPs, it is important that distributors can positively match the end investor to a particular product and where there is a mismatch, they need to be able to rectify this quickly. By providing your distribution network with the right data, including EMT and EPT, you can ensure they remain compliant and do not mis-sell to end investors.
For more information about our online digital platform and how it can ease the burden of regulation, please contact our business development team.
By Lee Godfrey