The great stampede is underway, the headlong rush of asset management firms to get their EPT (PRIIPs) and EMT (MiFID II) templates into the data exchange marketplace is well and truly underway.

Much like the great wildebeest migrations on the plains of Africa, there are unfortunately more than one water buffalo looking forlornly across the river at the herd on the other side. So what should you do if you find yourself on the wrong side of the river?

Some firms are prioritising their EPT above the EMT in order to ensure that they at least have their EPT in play. Why so? Well if a firm has been requested by an insurer to deliver EPT, that insurer would be obliged to pull any PRIIP offering including that investment product from the shelf unless they had some other way to safely produce the KID and any related documentation (e.g. signpost documentation / SIDs) for any applicable PRIIP. This would not only be a disaster for the manager in question as they would lose flows, but would potentially damage their working relationship with a key distributor.

Some managers have also expressed a notion that EPT can be used by a wealth manager to substitute for the EMT. All I can say here is that every wealth manager I have raised this with has indicated they will not accept EPT as a valid replacement for an EMT. They are already under huge pressure to implement formal product governance and investor disclosure functions based on collection of 100’s, if not 1000’s of EMT documents, and have no inclination to attempt to work out how they could use an EPT as a replacement.

Are there fast-track approaches to the EMT? Thankfully yes. Firms like our own (#shamelessplug) have EMT template production solutions that can fast-track the production of a template and facilitate its availability across a broad breadth of wealth managers and insurers.

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