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How Prudential is supporting advisers with MiFID II and IDD

MiFID II & IDD

From 3rd January 2018, new disclosure requirements came into play for MIFID financial instruments under the MIFID II directive.

Similar requirements, as a result of the Insurance Distribution Directive (IDD), came into effect on 1 October 2018 for insurance based investment products.

Please see our Frequently Asked Questions about MiFID II & IDD disclosure for more information.

Our costs & charges information

Initial (ex-ante) disclosure

As a ‘distributor’ of our products, you need to provide your clients with details of all the costs & charges they’ll incur as result of making their investment. This will include product and fund charges, any additional services charges and your advice charges. You also need to show your client the effect that these will have on any future return.

We provide you with information that is sufficient to meet the product costs & charges element only. You need to let your clients know about any other costs & charges they may incur (in some form of durable medium).

The following explains this in more detail.

  • MiFID II
    Where your client has invested in any of our OEIC funds, including within the Prudential ISA, Link Fund Solutions will send them a costs & charges disclosure document each year. The reporting period will follow the calendar year. Your client can expect to receive this information in the post at the end of the first quarter of the following year.

  • IDD

    The IDD disclosure requirements apply to you if you are involved in ‘insurance distribution activities’; such as advising on insurance-based products. This applies to new business, top ups, fund switches and exercising options under an existing contract in scope of IDD.

    Disclosure documents, such as the PRIIP KID, include all the relevant product costs & charges information required under COBs; however, these documents will not include details of any distribution costs & charges. These will need to be disclosed separately in a durable medium.

Periodic (ex-post) disclosure

  • MiFID II

    Where your client has invested in any of our OEIC funds, including within the Prudential ISA, Link Fund Solutions will send them a costs & charges disclosure document each year. The reporting period will follow the calendar year. Your client can expect to receive this information in the post at the end of the first quarter of the following year.
  • IDD
    For some of our products, your client’s annual benefits statements (ABS) already disclose costs & charges. Where the ABS for other products are in an older format, we are aiming to meet the periodic reporting requirements for insurance based investment products by 1 October 2019.

    Where your client has invested in PruFund through the life policy, within the Prudential ISA, Link Fund Solutions will also send costs & charges information annually to your clients. This will meet the ongoing disclosure requirements of product costs & charges under IDD.

    Remember that where you are providing an ongoing service, you’ll also need to periodically provide your client with details of other costs associated with services and transactions undertaken during the reporting period, not covered in the disclosures above.

Inducements

You’ll need to let your client know that, although we don’t pay you for recommending a Prudential product, we do offer you other support. This requirement applies for all products falling under MiFID and IDD.

To help you explain this, we’ve created a handy inducements document called ‘How we are supporting financial advisers’ which we include in all pre-sales packs for products open to new business.

Remember that you’ll need to make the same disclosure for clients looking to top-up an existing product, and you can download the document here.

You can find more information on the disclosure requirements under MiFID II & IDD on the FCA’s website.

Our target Market Information

As a manufacturer of products and funds which are in scope of MiFID and IDD, we’re required to provide you with target market information for these products.

These documents explain who we believe the products are, and are not, suitable for. Naturally, this is based on Prudential’s opinion and don’t take into account your clients’ individual circumstances.

We provide this information only for products open to new business.

Naturally we want to ensure that our products continue to be sold to their intended target market. Please share any feedback with us via your Prudential account manager. 

To make things simple, we’ve divided this section into ‘MiFID II’ and ‘IDD’.

MiFID II disclosure

IDD Products

© Prudential 2019