There are two ways of looking at the introduction of the Packaged Retail and Insurance-based Investment Product (PRIIPs) rules from an insurer perspective: the first is to bemoan, justifiably, the increased burden they now face, and the difficulties in extracting the data for the Key Information Document (KID) from the disparate snippets of information available to them; the second is to consider any overlap with various other pieces of regulation and to see how to implement the rules in the most efficient manner taking into account the foundations that have been laid elsewhere.
The latter is the path we obviously support; pleasingly it’s the attitude that many in the industry are now taking at this time.
Why now? We think that the introduction of the rules at the start of the year has in fact created a pause that’s been useful in allowing people to step back from the fray. The run up to the introduction in the final few months of 2017 was frenetic, and companies were desperately putting operations into place to ensure they were compliant come Jan 1. Some of the framework, given the hurried nature of the run up, was piecemeal and patchy and implemented purely to get the companies over the line. Thus, the fact that many are now evaluating their processes in a wider context.
This makes sense – the one key feature of PRIIPs is that the data required for it comes from exactly the same source as the data needed for Solvency II, namely the asset managers. A scalable and industrialised process for collecting the data for Solvency II should be readily transferable to PRIIPs. And the internal system insurers have for managing the data can and should be easily turned to this task too, even with the obvious differences between the two sets of rules. These synergies subsequently feed through into greater operational efficiency, allowing the marketing and sales departments quicker access to the key information they need to target investment products to the right consumers.
Looking forward, this common and standardised approach to data collection is then ready for the next set of rules that arise, whether that’s PRIIPs II, or MiFID III, or whatever!
Of course Silverfinch is already in place providing a standardised approach to Solvency II, PRIIPs and a host of other regulations. By singing up insurers instantly get all the data they need in the TPT and EPT formats, and with close to 95% of the market live or in the Silverfinch process, that means the data is ready and waiting. Still, with or without Silverfinch, the simple efficiency of combining the regulatory response to PRIIPs and Solvency II is there for insurers to grasp.