Submission #13

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Movement for Risk Transparency

1. Do you have any views on how draft RTS for the KID might be integrated in practice with disclosures pursuant to other provisions? Rita Laura D'Ecclesia

6: Do you think that performance scenarios should include or be based on probabilistic modelling, or instead show possible outcomes relevant for the payouts feasible under the PRIIP but without any implications as to their likelihood? See file attached.

7: How would you ensure a consistent approach across both firms and products were a modelling approach to be adopted? See file attached.

8: What time frames do you think would be appropriate for the performance scenarios? See file attached.

9: Do you think that performance scenarios should include absolute figures, monetary amounts or percentages or a combination of these? See file attached.

11: Do you have any preferences in terms of the number or range of scenarios presented? Please explain. See file attached.

13: Do you have any views, positive or negative, on the different examples for presentation of performance scenarios? Please outline advantages and disadvantages, and provide any other examples that you are aware of that you think would be useful. See file attached.

19: Do you agree with the costs and charges to be disclosed to investors as listed in table 12? If not please state your reasons, including describing any other cost or charges that should be included and the method of calculation. See file attached.

27: In terms of a possible breakdown of costs, are you aware of cost structures for which a split between entry or exit costs, ongoing costs, and costs only paid in specific situations or under specific conditions, would not work? See file attached.

Name of organisation Movement for Risk Transparency