Austrian Federal Economic Chamber, Division Bank and Insurance

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.

Filed in German · English published by the European Commission

1. Implementation Basel IV – Costs and Benefits According to EBA and ECB (Basel III reforms: impact study and recommendations) the cost of implementing the final Basel III reforms in the EU such as possible increases in capital requirements for banks would appear to be outweighed by the benefits for the economy as a whole, in particular over the longer term.

The Division Bank and Insurance of the Austrian Federal Economic Chamber, as legal representative of the entire Austrian banking and insurance industry, appreciates the possibility to comment on the Inception Impact Assessment. We would like to note the following comments and remarks. In general, we support this initiative.

ad Articles 23(2a) and 23(3a) of the Prospectus Regulation: We highly appreciate the proposal that the expiry date of the amendments for the extension of the timelines should be removed so that the amendments be permanent.

The implementation of the benchmark regulation alone is associated with a high level of effort. The corona pandemic is now exacerbating this. As is already being applied or discussed in other legal areas, the change in the Benchmark Regulation should be used to extend the transition period - which has already been once extended by the amending regulation on the introduction of sustainability-related benchmarks (EU…

Dear Sir or Madam, The arguments summarized in the EC Call for Evidence paper are true and fully supported. They largely focus on secured funding provided to other financial participants. However, it should be emphasized that many of the arguments mentioned also apply to unsecured placements. To be more precise: 1.

We especially welcome the European Commission’s readiness and efforts to review, in the common interest, the myriad of rules and provision in this field. A joint dialogue of all stakeholders involved (authorities, consumers, industry) can lead to optimal results, especially for consumers. We appreciate the Commission’s evaluation that the MIFID II/MiFIR framework needs an appropriate rebalancing of the provisions.