Retail investor protection rules

Financement Participatif France (FPF) strongly supports the ambition of the European Commission to increase the participation of retail investors in capital markets. However, we would like to seek clarification regarding the proposed modifications to Article 24a concerning inducements.

FBF shares the ambitions of the RIS and notably welcomes the provisions aimed at improving transparency and promoting financial education but is extremely concerned about certain provisions of the proposal. It would be regrettable if the RIS were to become an obstacle to the objective for which it was designed: stimulating productive investment by European citizens to finance the green and digital transitions.

AMAFI strongly supports the European Commissions (EC) objective of increasing retail clients participation in capital markets to help meet the financing needs of the EU and achieve the investment objectives of EU savers.

The EBF supports the objective of the RIS to enhance retail investor safe participation in EU capital markets. The EBF appreciates proposed elements like digital-by-default communication, efforts to streamline disclosures and further financial literacy, but expresses substantial concern over the complexity, unclear implementation pathways, and negative impacts that far-reaching measures may produce without being…

We fully support the Commissions ambition to boost retail investor participation in capital markets to finance EU economic development, the digital and sustainable transitions and the strengthening of EU sovereignty. However, we consider that the proposal only partially fulfils these objectives and may even have detrimental consequences.

AFG shares the objective of increasing citizens participation in capital markets, and extends a warm reception to the RIS provisions aiming at promoting financial literacy, which is an essential lever for directing retail investors savings toward long-term financing of the economy while ensuring their protection.

BVI, the German investment funds association, supports the Commission's stated goal of broader participation of retail clients in the capital markets. It is essential to encourage private investors to benefit from the opportunities of the capital markets. However, we feel that many of the proposals are not helpful for achieving this goal, while some others are probably outright counterproductive.

The Polish Chamber of Insurance (PIU) is a statutory organization of industry self-government. It was established in 1990 and represents all insurance companies operating in Poland. PIU is grateful to the European Commission for the opportunity to present comments on the proposal of the Retail Investment Strategy (RIS).

In the set of recommendations attached to this submission, AFME outlines our detailed views on the European Commissions Retail Investment Strategy proposals for the Omnibus Directive amending, among others, the Markets in Financial Instrument Directive (MiFID) and the Regulation amending the Regulation on key information documents for packaged retail and insurance-based investment products (PRIIPs).

BPCE is in favor of the Commission's initiative to empower retail investors in the CMU but believes that some proposals need to be amended first. First, the EC objective of improving financial education is essential.

Paris Europlace agrees with the RIS objective of attracting more retail investors to capital markets, but believes that fundamental issues in the proposal should be addressed first. Several proposals, including cost-centric value for money (VfM) & benchmark tests, an inducement ban for all non-advisory transactions, cheaper but incomplete independent advice, impracticability of a 3-year review clause, will not only…

FEDMA welcomes the European Commission's proposed Directive under the Retail Investment Strategy (RIS). Specifically, as part of our mission to defend a thriving environment for marketers powered by users trust, we share the proposals objective to protect consumers from misleading marketing communications.

Credit Agricole Group (GCA) welcomes the intention of the European Commission (EC) to help retail investors to better engage in financial markets. However, it believes that many proposals of the Retail Investment Strategy (RIS) would be counter-productive in this matter, as it appears to be at odds with the interests of a vast majority of investors with modest financial portfolios.

Amundi welcomes the European Commissions (EC) intention to empower consumers to invest in capital markets. Among the measures proposed by the EC in its Retail Investment Strategy (RIS) package, some of them are undoubtedly going in the right direction, notably the extension of the professional clients opt in under MiFID, the focus on financial literacy or the regulation of fin-fluencers.

Insurance Europe supports the goal of the Retail Investment Strategy (RIS) to increase retail participation in financial markets, while protecting investors from unfair practices. Within a well-designed legislative framework, insurance-based investment products (IBIPs) are key to enabling consumers to invest with confidence in capital markets, access insurance protection and prepare for old age.

Insurance Sweden´s response to the European Commissions Have your Say consultation on the Retail investment strategy new package of measures to increase consumer participation in capital markets Insurance Sweden is the industry organisation for insurance and occupational pensions undertakings in Sweden.

Executive Summary DUFAS welcomes the opportunity to respond to their extensive reform proposal of the EU legislative framework for retail investments, the Retail Investment Strategy (RIS) as published on 24 May 2023. We strongly support the objective of the RIS to boosting better access of retail participation in the financial markets. We do appreciate the European Commission's comprehensive work in this field.

On behalf of Caspar Towarzystwo Funduszy Inwestycyjnych S.A., a Polish fund management company, we present the following comments on the Retail Investment Strategy Package ("RISP"). Caspar strongly supports the European Commission efforts aiming at enhancement the retail investors to invest in financial products.

APFIPP is the Portuguese Association of Investment Funds, Pension Funds and Asset Management, representing the interests of Portuguese Asset Managers (UCITS and AIF Management Companies and Investment Firms performing Portfolio Management) and Pension Funds Managers.

The Generali Group wants to contribute positively to this debate and to foster a positive investment culture across the EU. We are therefore open to dialogue with all European regulators to ensure that the Retail Investment Strategy truly achieves its objectives. Please see attachment.

ANASF, Associazione nazionale consulenti finanziari, is the national association representing financial advisors authorised to offer investment services off the premises of financial intermediaries (consulenti finanziari abilitati allofferta fuori sede) registered in the official national register pursuant to Article 31 of the Consolidated Law on Finance (Legislative Decree no. 58/1998).

DDV (Deutscher Derivate Verband) appreciates the efforts of the European Commission (EC) to progress towards more protection, and further facilitation and empowerment of retail investors in its proposal for an Omnibus Directive as regards the strengthening of Union retail investor protection rules.

Ireland is a global hub for (re)insurers, captives and insurtechs. Irish insurers service customers across the EU, making Ireland the fourth largest insurance market in the EU and no.1 exporter of life and non-life insurance. Irelands life insurers have an outstanding expertise in providing high-quality services to their customers and allowing them to participate in capital markets.

The General Council of Economists appreciates the opportunity to send comments to the Consultation on the proposal for a Directive amending Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments.

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The Polish Bank Association (Związek Banków Polskich) welcomes the opportunity to present the comments to the Proposal for The Directive of Tth European Parliament and of The Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules. Please find enclosed the opinion of the Polish Bank Association.

The VVO (Austrian Insurance Association) generally supports the Retail Investment Strategy's goal of helping retail investors achieve higher returns and raise confidence in the capital markets in order to increase their participation in the European capital markets. The VVO welcomes the RIS proposal on financial education.

On 24 May 2023, the European Commission published a draft for the amendment of the PRIIPs Regulation (PRIIPs Draft) within the framework of its Retail Investment Strategy (RIS). The German Banking Industry Committee (GBIC) welcomes the intention of the European Commission to also revise the PRIIPs Regulation within the framework of the RIS.

The German Banking Industry Committee (GBIC) supports the European Commissions intention to use the retail investment strategy (RIS), developed as part of the capital markets union, to make the securities business more consumer-friendly and thereby encourage retail investors to invest in EU capital markets.

Although it was not politically possible to ban inducements in this in this instance a reform that will be necessary eventually to establish competition for product quality on retail investment markets - the proposal still includes several significant improvements over the status quo, which BEUC appreciates.

Key points (See full response in attachment): - EFSA wants to highlight that from a CMU-perspective it is important to always make the competitiveness and attractiveness of EU capital markets, including for EU market participants such as SMEs, a part of the impact analysis. This is in particular the case as the UK has announced that it intends to simplify its regulatory framework.

Ladies and gentlemen, please find attached the opinion of the AFW Bundesverband Finanzdienstleistung e.V., including an opinion stating that parts of the draft are contrary to applicable European law. Highly respected Norman Wirth Executive Board

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Dear Sirs Our platform gives clients access to over 400 domestic (Warsaw domiciled) and foreign funds (passported from EU). At the same time, we do not reward our employees or evaluate their work in a "commission" way or contrary to our duty to act in the best interests of our clients.

As 6th largest exchange group in Europe, Boerse Stuttgart Group welcomes the opportunity to express its views on selected topics included in the EU Commissions Retail Investment Strategy(RIS). 1) We strongly support the exclusion of corporate bonds with a make-whole call from the PRIIP regulation and ask for quick adoption of the amendment We welcome the EU Commissions proposal to amend the PRIIP regulation to the…

Retail investment is a very important regulations for the capital market, having a huge impact on the activities of investment funds. Therefore, on behalf of the Ipopema Towarzystwo Funduszy Inwestycyjnych S.A., I submit the attached comments on Retail Investment Strategy Package (RIS), agreed with the Izba Zarządzających Funduszami i Aktywami.

Key points We are opposed to any changes to existing incentive rules. When implementing the Strategy, it should be borne in mind that the regulatory framework should enable the coexistence of various business models existing in individual EU countries. The idea of establishing EU central benchmarks is damaging to smaller capital markets.

The European Fintech Association (EFA) welcomes the European Commissions proposal to fulfil the Capital Markets Union's (CMU) objective of ensuring that consumers can fully benefit from the investment opportunities offered by capital markets, through its Retail Investment Strategy (RIS).

The draft directive is part of the implementation of the retail investor strategy (RIS), which aims to ensure that consumers investing in capital markets can do so with confidence and confidence, that the results of these investments are improved and that consumers are more involved. The present draft does not meet its own objective of gaining consumer confidence in the capital market.

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Brokers Ireland is Irelands representative body for insurance and financial brokers in Ireland, with a combined strength of over 1,225 firms. Brokers Ireland is a member of BIPAR the European Federation of Insurance Intermediaries, which groups 47 national associations in 30 countries, representing 800,000 intermediaries throughout Europe.

LPEA's comments on the RIS proposal: The LPEA is representing the Private Equity & Venture Capital community in Luxembourg. Private Equity strategies are inherently more innovative than more traditional investment strategies: however benchmarking and the induced higher costs thereof may hide innovation for non-mainstream products, and notably venture capital.

Finance Finland supports the development of investor protection, but we see that the Commission has not chosen successful means to achieve the goals. The presented problems could be better avoided by strengthening supervision instead of introducing new regulations that hinder the market-based functioning of the capital market.

Finance Denmark (FIDA) supports the aims of the Retail Investment Strategy (RIS) to enhance retail investor participation and protection, and to ensure that investors are offered high-quality advice for products and services, which bring them value for money. However, we are concerned with the narrow focus on costs, and we generally find that the effects of the package might not reflect the Commissions intentions.

Distinguished ladies and gentlemen, Thank you for allowing us to express our opinion on the proposed Retail Investment Strategy Directive. Ascofind is an Italian association of independent financial advisory firms. Firstly, we would like to welcome the Commission's proposal for a directive which introduces numerous changes to the existing legislation in order to enhance investor protection.

The European Public Real Estate Association (EPRA), the voice of Europes listed real estate companies, welcomes the EU retail investment package as a means to enhance greater retail participation in EU capital markets.

LASF (Association française des sociétés financiers) represents 254 members, financing companies, specialised banks or credit institutions, investment firms, management companies, payment institutions and electronic money institutions, whose common feature is the provision of specialised financial services and financing to businesses and households.

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In the context of the public consultation on the roadmap, FAIR underlined the lack of EU label on sustainability related information, as well as the lack of financial products that would meet sustainability preferences, two interesting stakes that were put forward in the consultation form. However, we fear that the sustainability side remains rather underexploited in this proposal for a directive.

Please find attached the opinion of the German Chamber of Commerce and Industry (DIHK) on the Proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards Union rules for the protection of retail investors (Retail Investments Directive) (2023/0167(COD)) of 24 May 2023 with a request for consideration in the…

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The ABBL welcomes the underlying objectives of the Commissions proposal to reinforce investor protection within the European Union (EU), to foster trust in the financial sector and to promote participation in capital markets.

The German Sustainable Finance Advisory Committee, an independent advisory body consisting of high-level representatives from the financial sector, real economy, civil society and research, welcomes the fact that the Commission has proposed to amend Article 8(3) of the PRIIPs Regulation (1286/2014) to also address the important issue of sustainability in the PRIIPs KIDs.

Following the publication of the EU Commissions Retail Investment Strategy (RIS), I am writing to share The Investment Association's (IA) perspective. Attached you will find our position paper in response to the Strategy. The IA welcomes the EU's commitment to bolstering retail investor participation and enhancing investor protection.

On 24th May 2023, the European Commission presented a proposal for a directive on retail investor protection to encourage and support retail investors participation in capital markets. With this response to the consultation, the European Federation of Financial Advisers and Financial Intermediaries (FECIF) aims to present its comments on the proposed directive.

1. The Advertising Information Group (AIG) (transparency number: 11220347045-31) welcomes the opportunity to respond to the European Commissions proposal for a Directive amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules published in May 2023.

Dear Sirs, Please find attatched the Portuguese Association of Insurers (Associação Portuguesa de Seguradores - APS) position regarding the Retail Investment Strategy (RIS). APS is a non-profit association, established according to the law to defend and promote the interests of the insurance and reinsurance companies operating in the Portuguese market.

As a leading professional body for financial advisors and planners in EU, gathering a community of over 90 000 professional certificate holders, at EFPA we believe that today it is one of our key goals and motivations to make skills matter in the process of implementing the new RIS.

French Insurers support the texts objective to increase citizens safe participation in capital markets by strengthening their access to financial products and appropriate advice. We welcome the new measures on better understandable information and digital by default, the push for financial education and the drive to simplify precontractual information.

Many provisions included in the proposals will make consumers investment journey longer, more complicated, and intimidating than before. Steps were added to the very long purchase process under both the suitability and appropriateness tests, the reporting and record keeping requirements are increased.

The feedback/opinion of the Federal Association of German Asset Advisers can be found in the Annex. The BDV is registered in the European Commission’s Transparency Register under reference number 227018443661-69. Yours sincerely, [name removed], Managing Director

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I. Digital communication support The Czech Insurtech Association would like to express support for the European Commission's proposal regarding the prioritization of digital communication with customers within the framework of the Retail Investment Package.

We strongly welcome the efforts of the EU Commission to significantly improve the situation for household investors in Europe. The background to this is that private households in Europe invest significantly less in the capital markets than in other countries. Why is it important for households to invest and participate in the capital markets? Companies go public to raise money for their further developments.

DECO welcome the proposal of a Directive under the Commissions Retail Investment Strategy (RIS). The overall objectives of increasing retail investors protection and access to information and knowledge are shared goals with consumer organisations.

Where advice comes up, there must be independent advice! Commissions represent a structural problem in the financial market: Consumers turn to a financial adviser if they see a need for information and advice in the context of an investment decision. As a result of financial advice, they expect a recommendation according to their needs, in particular their risk appetite and risk-bearing capacity.

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The European Commissions package of proposals on RIS aims to amend the existing MiFID, IDD, UCITS, AIFMD, Solvency II and PRIIPs regulatory framework in order to increase the participation of retail clients in the EU capital markets, enable more informed investment choices on the basis of easily understandable and comparable information, and improve the manufacturing and distribution process of financial products…

The fundamental aim of the EU Retail Investment Strategy (RIS), namely strengthening retail investors participation in Europes capital markets, is to be supported. The German Association of Public Insurers (VöV) therefore appreciates the opportunity for consultation and is ready to lend constructive support to the implementation process.

ABI supports the creation of the CMU and its objectives, including that to facilitate retail investor participation in the EU capital market. The Retail Investment Strategy, however, proposes regulatory changes that would have a significant impact on the financial industry, adversely affecting the development of the EU capital market.

Assogestioni fully supports a number of the proposed measures while is of the view that others raise critical issues, also stemming from the extensive referral to Level 2 implementing rules, the impacts of which are currently difficult to assess.

The German Savings Banks Association supports the intention of the European legislator to use the Retail Investment Strategy (RIS) to make investment processes more client-friendly and thus to strengthen the participation of retail investors in the capital markets. In particular, we wel-come the (temporary) refraining from a complete ban on inducements.

Assoreti Association of intermediaries which provide investment advice service through their network of qualified natural financial advisors is grateful to the European Commission for the opportunity given to hear its views on the Retail Investment Strategy.

ESBG supports the European Commission's view that boosting the Capital Markets Union, by strengthening the participation of retail investors in the capital markets, is an essential way to channel private finance into the economy and support the green and digital transitions.

Spanish Banking Association (AEB) welcomes the opportunity to comment on the Proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the union retail investor protection rules and the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 1286/2014 as regards…

Spanish Banking Association (AEB) welcomes the opportunity to comment on the Proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the union retail investor protection rules and the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 1286/2014 as regards…

For further inquiries: [name removed], Chairman Austrian Financial and Insurance Professionals Association, AFPA Albertgasse 35/1, 1080 Wien tel: [phone removed] email: [email removed] www.afpa.at AFPA, founded in 2011, is the independent industry association of Austria's self-employed insurance intermediaries and financial advisors and a member of the European industry association FECIF, based in Brussels.

France Invest fully supports the European Commissions objective to develop a coherent regulatory framework to empower consumers, enhance their participation in EU capital markets and help improved market outcomes.

The ACA wishes to express its concern about the impact of these texts on our members. The multiple bans proposed, the many additional requirements will complicate consumers’ access to capital markets considerably, which is the exact opposite of what the European Commission is seeking to achieve with the IPM.

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CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules. Please find attached our considerations.

UNESPA is the Spanish Association of Insurers. It was founded in 1977 and represents approximately 200 insurers that together cover almost all the insurance business in Spain. These undertakings have a turnover of 62,000 million euros every year, or in other words, almost 5.1% of Spanish GDP.

ASPIM welcomes the ECs compromise not to fully ban inducements. However, in practice, the new obligations set forth by the RIS make it essentially inapplicable. As a consequence, this would virtually eliminate the commission-based model, effectively depriving the most modest investors of access to advice while also making many financial products no longer available from financial intermediaries to institutional…

Omnibus directive: To protect investors from being affected by excessive costs and services not aligned with their investment objectives or not offering any added value, as well as from potential conflicts of interests, ALFI believes that it is crucial to offer a clear, transparent overview of costs, their structure and services attributed.

ANACOFI shares many of the observations made by the European Commission and the Parliament. It is in favor of the objective of simplifying the pre-contractual relationship and adapting the source texts relating to retail investment, in order to better integrate technological developments and the desire to strengthen the ESG dimension of investment. .

AILO represents the interests of life insurers which write life insurance and pensions business on a cross-border basis throughout the EU and other jurisdictions. We are pleased to see the Commissions initiative to promote investment in capital markets. In the long-term investors will be left behind if they only invest in assets which are near risk-free.

Report by the Avisory Committee of the Spanish National Securities Market Commission on the European Commission's Retail Investment Strategy proposal. The Advisory Committee of the CNMV has been set by the Spanish Securities Market Law as the consultative body of the CNMV.

Zurich Insurance would like to thank the European Commission for the opportunity to provide feedback on the recently published Retail Investment Strategy. Zurich greatly supports the objectives of the Retail Investment Strategy to foster EU retail investment and empower consumers to invest for the benefit of the EU economy, financing the green and digital transition and closing pension gaps.

Referring to the ALFI response to the EC consultation strategy for retail investors, we propose the EC to perform targeted modifications of legislation especially in the following areas: Investor categories - We welcome the EC’s intention to tackle overly restrictive protective measures for investors with sufficient knowledge and experience.

We welcome the Commission’s intention to strengthen consumer participation in the development of capital markets. However, we cannot confirm the reasons given which lead to a lack of consumer participation in the markets and the statement that a "weak reliability and quality of the investment advice provided" can be observed for the European market.

AMAFI has the following comments on: • Product Governance Shares and bonds should be removed from the scope of Product Governance rules.These were primarily designed for structured products and their application to shares and bonds is unsuitable and does not provide added protection to retail clients while discouraging firms from distributing them to such investors.

BEUC welcomes the opportunity to comment on this Initiative to remedy malfunctioning retail investment markets in the European Union. The current ruleset in the Markets in Financial Instruments Directive and Insurance Distribution Directive have not proven effective, which is apparent in the underperformance of many retail investment products compared to the market average.

2022 05 31 – France Assureurs on EC Call for Evidence on RIS France Assureurs shares the EC’s ambition to increase retail investors’ confidence and trust in the capital markets. A stronger retail investment flow in the European economy would help support the European recovery, finance the double transition (digital and sustainable) and to find responses to an ageing population.

The Polish Insurance Chamber (PIU) would like to point out that the invitation to the European Commission to submit comments on the legislative initiative on retail investment does not specify in detail the problems identified by the Commission, nor does it indicate the specific proposals under consideration. It is therefore not possible to assess the proposed solutions in detail and to provide relevant comments.

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BME response to the Commission’s call for evidence on the retail investment package 31st May 2022, Madrid The lastest years, pairing the COVID crisis as well as its recovery, together with the increasing importance of capital markets have made ever more relevant the role retail investors play in the financial landscape as catlysers for a more dynamic and sustainable financial ecosystem.

Amundi is the largest European asset manager by assets under management and amongst the top 10 globally. It manages around 2,000 billion euros of assets across six main investment hubs in Boston, Dublin, London, Milan, Paris and Tokyo.

1. AFME responded to the European Commission’s EU Strategy for Retail Investors consultation on 3rd August 2021. Inducements and quality of advice AFME members are not supportive of establishing an outright ban on inducements.

As a pan-European financial services provider Trade Republic Bank GmbH welcomes the opportunity to comment on the Call for Evidence and would like to raise the following points the European Commission attention: We strongly agree with the Commission’s assessment that the level of retail investor participation in EU capital markets remains low despite high individual savings rates in Europe.

No ban on inducements:we are in favor of keeping the choice between commission-based and fee-based model.The current legal framework on inducements is appropriate to protect clients against potential conflicts of interest.A ban on inducements -that would leave room only for the fee-based model- will inevitably lead to an advice gap for retail clients and only a small number of wealthier investors would continue to…

BIPAR welcomes the opportunity to comment on the European Commission’s Call for evidence for an evaluation and impact assessment run in parallel regarding the Retail Investment Package initiative. In line with previous BIPAR input provided on the same issue at the occasion of other Commission/ESAs consultations, please find attached BIPAR comments.

The French Banking Federation (FBF) welcomes opportunity to comment Retail Investment Package and thanks DG FISMA for attention given to it. MiFID II, PRIIPs, IDD and UCITS are consistent and appropriate according to stakeholders.FBF doesn’t share rather negative diagnosis since no major difficulties are identified by a study.

2° Investing Initiative (2DII) welcomes the Call for Evidence in relation to modernising and updating the investor protection rules and establishing fully coherent and consistent regulatory requirements across the EU. Measures to increase consumer participation in capital markets must similarly address increasing consumer preferences for sustainable investment.

ICI Global believes that the EU’s regulatory framework for retail investment contains important protections but could be updated to better empower retail investor engagement in EU capital markets, particularly on a cross-border basis and when investors are using digital technology.

The EU retail investor protection framework provides a solid basis to protect retail investors when investing in capital markets. However, the fragmentation of the investor protection rules across a multitude of legal texts as well as the lack of alignment of the rules entails that some of the rules are difficult, if not impossible, to be applied by professionals and understood by consumers.

EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets. In our view, the patchwork of rules currently governing retail investor participation is either misaligned or tends to focus too narrowly on investor protection and on the risks associated with investing.

In its ‘call for evidence’, the Commission states on page 2 that ‘EU consumers do not sufficiently benefit from capital markets, in particular because of a lack of market access and in order to meet the higher retirement age’.

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As the Italian Banking, Insurance and Finance Federation (FeBAF), we agree with the importance of adopting measures to increase retail investment in capital markets. In view of increasing retail investment in capital markets, this is we believe that the main regulatory options should aim at: • ensuring more coordination between the different pieces of EU legislation (MiFID II, PRIIPs, IDD) and remote any additions…

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The Call for Evidence does not provide sufficient detail on the magnitude of the problems identified or the concrete proposals under consideration. Respondents are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear, making it difficult to provide meaningful feedback.

We welcome the goal of reinforcing the participation of retail clients in the capital markets. This is particularly necessary due to the low interest rate environment and, in particular, for funded retirement provision. However, we believe it is necessary to carefully examine which measures help and which, if any, may be more of a deterrent for customers or are not advisable in light of a cost-benefit comparison.

We agree that the problem of low financial literacy is relevant and that targeted financial education initiatives are needed, as is the education activity carried out by financial advisor to clients. The PRIIP Regulation has improved the comprehension of investment products. An assessment of its effectiveness will only be possible when it will be effectively implemented.

“Zertifikate Forum Austria (ZFA) supports the Commission’s objective to ensure that the legal framework for retail investments empowers consumers, enhances their participation in the capital markets and helps ensure improved market outcomes. Please find our full feedback in the attached document.”

The Call for Evidence does not detail the magnitude of the problems identified or the concrete proposals under consideration. We are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear making it is difficult to provide meaningful feedback.

A solid framework protecting retail investors is in place in the EU The Insurance Distribution Directive (IDD), Packaged Retail and Insurance-based Investment Products (PRIIPs) and Markets in Financial Instruments Directive (MiFID II), in place for <4 years, introduced strong and effective conduct rules in the retail investment markets across the EU.

Finance Watch welcomes the European Commission’s forthcoming evaluation and impact assessment on the retail investment strategy. Improvements are needed to the EU retail investor protection framework to ensure that EU citizens can safely invest in capital markets, both online and offline. Please find our full feedback in the attached document.

Our comments (see attached file) adress the following topics 1. Financial literacy 2. Information overload 3. Ban on Inducements/advisors’ remuneration setup: WE are convinced that banning Inducements and a mandatory switch to fee-based advice models would be detrimental to the overall aim of increasing retail investor participation. Many retail clients are either not disabling and/or willing to pay for advice.

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The full response of the Association to this consultation can be found in the PDF annex. In principle, we welcome the Commission’s intention to strengthen consumer participation in the development of capital markets. However, contrary to the Commission’s findings, we cannot confirm the reasons which allegedly lead to a lack of consumer participation in the capital markets.

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We respond on behalf of the European private equity industry. While typically private equity funds are not offered to retail investors, some managers have recently set up structures that allow investors that are neither professional nor sophisticated to access the asset class. This is for example the case of managers setting up “ELTIF” vehicles.

Boerse Stuttgart Group fully shares the EU Commission’s object to empower retail investors. Investment should be made simple, less costly, transparent, and take steps to prevent conflicts of interest. In order to incentivise retail investor participation and financial planning, simple and cost efficient products must be easily available across the EU.

We strongly appreciate the Commission's commitment to a horizontal Retail Investment Strategy, which could become one of this mandate's flagship projects in financial services. Indeed, with increasing retail investor participation in financial markets and given developments in digitalisation and automation of retail financial service distribution, the Commission should ensure that the EU legislative framework builds…

We appreciate to have the opportunity to share our comments how to increase consumer participation in capital markets. GBIC is convinced that consumer participation can only be enhanced when clients are able to choose between commission-based and fee-based advice. Therefore, the GBIC is strictly against a ban of inducements.

We appreciate the opportunity to comment on the call for evidence. While we consider targeted modifications of existing legislation to be appropriate in some points, we are convinced that the current regulation on insurance-based investment products has, for the most part, worked well in practice.

Increasing retail investors’ access to capital markets will be vital if Europe is to secure a sustainable recovery. Europe needs to empower retail investors by making investment practices simple(r), cheaper, transparent, and by taking steps to prevent conflicts of interest.

Our view is that the Consultation Paper does not consider any of the potential risks, challenges and opportunities for retail clients in the context of cryptoassets. We feel that capital markets will have increasing participation in transacting cryptoassets and the goal of improved market outcomes will be dependent on how the regulation and supervision of cryptoassets is carried out.