Lausunto

Public consultation on a retail investment strategy for Europe

  • The existing EU rules regarding retail investors protect them through extensive disclosure and conduct requirements for investment service providers.
  • The introduction of MiFID II, IDD and PRIIPS has increased the complexity of information to be asked from and given to the retail investor.
  • Information overload doesn’t mean better protection for the retail client.
  • The existing limitations restrict the range of investment instruments that can be offered to the most experienced retail investors.
  • PRIIPs have increased comparability between the same types of products but not between different types of products.
  • The suitability assessment in MIFID and IDD is too detailed and takes too much time. Instead of introduction of an additional client category (semi-professional) of investors, we ask for adjusting the definition of professional investors on request.
  • Current MiFID and IDD rules on inducement have worked well in practice and there is no need to make any changes to the regulation.
  • The rules should not be aligned across MiFID and IDD.

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