The AMF has published Proposals to improve the readability of financial product fees in European law on the fees for financial instruments, together with a Draft glossary on financial investments fees (in French only), in order to improve savers‘ understanding of these fees as part of the ongoing discussions on the European Commission’s Retail Investment Strategy.
In compliance with MiFID II and, if applicable, PRIIPs, the distributor is obligated to furnish clients with pertinent information concerning costs and charges associated with financial instrument marketing. This information enables clients to make informed decisions.
Hence, the present proposal was developed in collaboration with the FSCC and focuses on improving the readability and comprehensibility of fees related to the subscription of financial instruments. The proposed table of fees is intended to feed into the European Commission’s reflection of the Retail Investment Strategy and is not an additional obligation for distributors to provide to clients. However, it would require an evolution of the MiFID II Regulation.
This table of fees is designed to conform to the PRIIPs KID fees classification, which includes one-off, ongoing, and incidental fees. This helps investors to understand the frequency of charges they can expect. The table can be adjusted to suit various financial instruments and investment services, allowing distributors to use only the relevant information.
The FSCC has also recommended that a glossary of financial investment fees, excluding life insurance, should be provided to investors along with the table of fees. This glossary can be provided separately to investors, as it is based on the types of fees currently presented in investment service provider documents such as fee brochures, prospectuses, PRIIPs KIDs, and so on. Unlike the table, the glossary is not conditional on changes in regulation.
To ensure that the glossary is understandable to investors, a qualitative readability study was conducted in September 2022, and the results were taken into account. Providing a glossary of financial investment fees will assist non-professional investors in understanding investment fees, enable them to make informed investment decisions, and harmonize the terminology used by professionals.