In the fifth article of our Blog Series on the new Consumer Composite Investments (CCI) regime, Seamus O’Cuill, Head of Investor & Digital Services at Funds-Axis, examines the proposed Product Summary and transitional arrangements outlined in recent Consultation Papers.
Manufacturer Responsibilities
Manufacturers are responsible for creating a Product Summary, the contents of which have been covered in previous articles. They must provide this summary to distributors, ideally by publishing it on their website.
Additionally, manufacturers must ensure the Product Summary is available in a machine-readable file, allowing distributors to integrate the information into their systems. While no fixed format has been prescribed, it is anticipated that FinDatEx or other industry bodies may update their templates to facilitate compliance.
Distributor Responsibilities and Investor Access
Distributors are accountable for ensuring all necessary information is made available to investors. A distributor may not offer a CCI for purchase or sale unless the required disclosures are accessible.
Before a sale, a Product Summary must be provided to retail investors. While distributors may modify this summary—such as adding information about extra costs—they must ensure the revised version remains compliant.
Following a sale, investors must receive a durable copy of the Product Summary for their records. Although email distribution is likely permissible, the FCA is currently seeking additional feedback on this aspect.
Transitional Arrangements
The following table outlines the proposed transition timelines for different product types:
| Product Type | Transition Period Options | Deadline for CCI Compliance |
|---|---|---|
| PRIIPs | Can adopt CCI rules immediately or continue following PRIIPs regulations until transition ends. | 18 months after PS and rules publication. |
| UCITS/NURS | Can adopt CCI rules immediately or continue following UCITS KIID regulations until transition ends. | 18 months after PS and rules publication. |
| Investment Companies with PRIIPs Exemption | Can adopt CCI rules immediately or retain exemption until transition ends. | 12 months after PS and rules publication. |
Machine-readable formats will only become mandatory at the end of the transition period to prevent manufacturers from delaying their adoption due to reporting complexities.
Industry Perspective
Seamus O’Cuill, Head of Investor & Digital Services at Funds-Axis, shared his insights:
“The FCA’s extended transition period aims to support manufacturers and distributors in meeting their obligations efficiently.
By the end of this process, manufacturers will need to provide:
- A Product Summary, accessible online.
- A machine-readable file for ingestion by distributors.
- A hard copy document for investors, though the distribution method is still under review.
It will be interesting to see how quickly firms adapt to the new regime. We anticipate that manufacturers will begin updating their websites early, while hard copy documentation transitions may align with year-end updates.
At Funds-Axis, we remain committed to guiding our clients through this evolving regulatory landscape.”
