Implementation of EU Packaged Retail and Insurance-based Investment products regulation (“PRIIPs”) | inaccurate or potentially misleading calculation results 

Since 1 January 2018, PRIIP manufacturers are required to provide a KID (Key Information Document) to retail investors, in advance of the sale of any PRIIP (whether an advised or non-advised sale).  PRIIPs include a wide range of products such as structured products, derivative instruments, certain bonds and investment funds.  The purpose of a KID is to equip retail investors with sufficient information in an easy-to-understand format and enable an informed investment decision to be made.


The PRIIPs regulation requires the KID to include future performance scenarios based on a specified calculation methodology.  This methodology utilises the recommended holding period as well as other points in time prior to the term of the financial instrument.  Further, the calculation is based on the historic performance of the underlying (including but not limited to the historic volatility). Based on this scenario values are calculated for the relevant financial instruments.


Notwithstanding that manufacturers are following the prescribed regulatory calculation methodology, we wanted to draw your attention to the fact that the results in some cases are producing potentially misleading results.  Performance scenarios are influenced by market conditions and market movements and can change over time. 

Some examples of potential inaccuracies include:


  • Potentially misleading performance scenarios for interim holding periods;
  • Returns in excess of one million percent


What you should do next 


In light of this information we ask that you consider all PRIIP product information carefully in making your investment decision.  Moreover we specifically ask that you apply caution in placing reliance on the performance scenario projections set out in any KID provided to you because performance scenarios are not reliable indicators for amounts actually paid to you. 

If you have any queries regarding the contents of this letter please contact your Client Advisor.


Yours Sincerely,

Deutsche Bank Luxembourg S.A.

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