“A number of respondents discussed the position of firms that provide dealing and custody services, such as the provision of what were referred to as: discretionary managed portfolios (DMPs), investment portfolio accounts, centralised investment propositions that enable the investment in shares of one or more investment trust companies, and propositions that enable investment in one or more Alternative Investment Funds (AIFs) or other securities,” the FCA said.
“We consider that the provision of a service, if it allows retail investors to purchase, hold and sell investments as legal or beneficial owner, is unlikely, itself, to be a PRIIP.”
It urged firms to “carefully consider” the services they provided to retail savers.
“They will need to assess whether there is any ‘packaging’ which intervenes between the retail investor and the investments, such that they might fall within the scope of the PRIIPs Regulation” the regulator said.
“In providing their service firms will also need to consider whether they have made changes to an existing PRIIP, and the extent to which any investments purchased or held using such services are PRIIPs for which a KID needs to be provided.
“Any costs or charges associated with investment services provided will need to be disclosed separately, if not reflected in the costs disclosed in a KID14.”
