Although there is no regulatory obligation for non-MiFID firms and fund manufacturers to complete European MiFID Templates (EMT) and European PRIIPs Templates (EPT), there are a few things asset managers should consider before deciding not to provide these to their distribution network.
- EMTs and EPTs provide distributors with the specific data they need to ensure they are compliant.
- The 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 but 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.
Effective dissemination is key
The complexity of dissemination is often underestimated when it comes to the recipient’s requirements. EMTs and EPTs 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 EMTs and EPTs 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.
Fund documentation and reporting made easy
Kneip can support you with MiFID compliance. We can help you gather your data in a single source of truth, run calculations for the different MIFID contexts (ex-post/ex-ante) and automatically feed into the section in Target Market of your EMT before it gets disseminated. The monitoring functionality also allows you to keep up-to-date EMTs and helps you to comply with the regulation.
We can also simplify and accelerate the process of ensuring PRIIPS compliance. With Kneip you have the flexibility to produce PRIIPs EPTs, CEPTs and KIDs in base language as well as in other destination languages. And you can trust that our experts continue to ensure that you remain compliant with the latest regulatory trends.
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.
Find out how we can help
Read more about our EMT and our EPT products, and how Kneip can simplify fund documentation and reporting.
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