- FFI sees that it is extremely difficult to respond to this consultation due to the limited information about the proposed regime under the consultation. It is unsecure whether this regime is meant to replace the current client suitability and appropriateness assessment under MiFID and IDD or whether it is meant as additional to the current assessment.
- FFI does not consider the full standardization or suitability and appropriateness analyses the preferrable option. The current suitability and appropriate tests work quite well, and there is no need to replace the regime with the enhanced client assessment regime.
- FFI doesn’t see a need for the transfer of the assesment between the service providers.