Retail Investment Strategy

Ireland is the 5th biggest market for insurance in the EU and the second biggest for reinsurance. Irish companies serve customers in more than 110 countries worldwide including 24 EU Member States. A key factor of the success of Irish insurers is the creation and integration of the EU single market, regulatory and supervisory consistency and convergence.

AFME is scratch for the opportunity to respond to the European Commission’s Roadmap for an EU strategy for retail investors. AFME welcome the European Commission’s planning towards a comprehensive strategy for retail investors, building on the CMU HLEF report of June 2020.

Filed in French · English published by the European Commission

Preliminary remark French banks have made great efforts to implement the various financial regulations and to improve the quality of services provided to their clients. They are now calling for regulatory stability to focus on priorities such as the completion of the CMU or the financing of the post-Covid recovery.

The Association of German Public Insurers welcomes the initiative of the European Commission to create a comprehensive Retail Investment Strategy in order to enable retail investors to make informed decisions while taking advantage of the European capital market.

Currently, investor protection rules are set out in a number of sector specific legislative instruments at EU level, while general consumer protection frameworks remain under national rules. In order to better reflect the variety of issues across member states, it would be useful to target especially retail investors responses to the consultation. Could this be done through the traditional consultation process?

As part of the roadmap of the EU strategy for retail investors, the French Insurance Brokers Reflection Group recommends taking into account elements of differentiation between the sale of financial products to retail investors and insurance products: — a life insurance contract is not a financial asset, — and an insurance broker is not a financial investment intermediary.

Filed in French · English published by the European Commission

2° Investing Initiative welcomes the initiative on a Retail Investment Strategy for the EU. A comprehensive strategy is essential to match the environmental and social ambition of the Green Deal and support and progress the retail investment focussed activities which began under the 2018 Action Plan on Financing Sustainable Growth.

Gisad welcomes the European Commission’s initiative to offer capital market products that are transparent in risk, understandable in the use of capital and directly beneficial to citizens. To this end, it is necessary to establish generally binding standards that guarantee the quality of the products created by the capital of the companies.

Filed in German · English published by the European Commission

BEUC welcomes the European Commission’s intention to adopt a new Retail Investment Strategy in the beginning of 2022, which is urgently needed to ensure that consumers are adequately protected when investing into capital markets.

Deutsche Börse Group appreciates the opportunity to provide feedback on the roadmap for a retail investment strategy for the EU as part of the CMU Action Plan. Over the course of the last years, in particular in 2020, we have seen positive developments in EU retail participation as well as a change in investor behavior.

Finance Denmark support the initiative of an EU Strategy for Retail Investors and suggest that the well-being of the investor is put at the center of the strategy. Consumer protection in the context of the CMU is about generating trust and transparency, whilst promoting a better investment and saving culture.

As an exchange that caters the needs for retail investors, Börse Stuttgart strongly supports the initiative by the EU Commission to look closely on retail investors participation in financial markets. We welcome the opportunity to participate in the Commission’s consultation on the EU strategy for retail investors roadmap.

Dear Sirs, Ascofind is an Italian Association gathering investment firms and financial advisory firms that offer investment advice on an independent basis. A recent Report on financial investments of Italian households, published in December 2020 by the Italian Authority Consob, reveals that only 33% of Italian savers access the financial markets.

The Association of German Debt Capital Platforms welcomes the opportunity to comment on the Commission’s roadmap to a new EU strategy for retail investors. We are absolutely supportive of the Commission’s objective to develop a coherent regulatory framework to empower consumers to make investments in the EU capital markets with confidence and trust.

GBIC welcomes the opportunity to comment on the Commission’s roadmap: 1. Inducements A potential ban on inducements would run counter the roadmap’s explicit aim to raise the level of participation by retail investors in financial markets.

We promote retail investment and develop the securities markets in Finland. Retail investment strategy is an important and highly welcomed initiative and we agree that the level of participation by European retail investors remains too low. Please see below for our comments about the roadmap: - Investor protection and disclosures rules differ between legislative instruments. These caps should be narrowed.

Invest Europe supports the European Commission’s objective to develop a coherent regulatory framework to empower consumers to make informed investments in EU capital markets. Traditionally, the private equity industry is only marketing to investors that are either institutional (pension funds, insurers, banks, sovereign wealth funds, fund-of-funds) or at the very least experienced (family offices, entrepreneurs).

Building on the CMU HLEF report of June 2020, Schroders welcomes the European Commission’s plan for a comprehensive strategy for retail investors. It is clear that enabling economic recovery and achieving sustainability goals will depend on engaging and motivating more individuals to invest in capital markets. To this end, it is essential to start with the investor, which involves looking at the entire value chain.

Time for change. This is the basis of this feedback. Time to support the proposal from the Portugese EU presidency to introduce in 2022 an EU Financial Transaction Tax, including the derivatives. This way the strategy for private investors is cleared from discussions, since they know from the start that they will have to take into account the FTT.