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Compare organizations

Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

AFP
AFPA

Industry association · Austria

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
GBI
German Banking Industry Committee

Industry association · Germany

37
files engaged
of 583 tracked
45
positions filed
in those 583 files
13
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: under €10K a year · in the register since 2009

Files both filed on (2)

Retail investor protection rules · Framework for Financial Data Access

Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.

What each said, in their own words

Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.

Retail investor protection rules

German Banking Industry Committee · filed 27 May 2022 · source

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.

AFPA · filed 31 Jul 2023 · source

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.

German Banking Industry Committee · filed 28 Aug 2023 · source

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.

German Banking Industry Committee · filed 28 Aug 2023 · source

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.

Framework for Financial Data Access

German Banking Industry Committee · filed 2 Aug 2022 · source

The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.

German Banking Industry Committee · filed 26 Oct 2023 · source

With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.

AFPA · filed 28 Oct 2023 · source

We would like to share our feedback on the consultation on the Open Finance Framework. We have included our comments in the separate attachment. Thank you very much for your consideration. We are happy to engage in a dialogue and provide further input and support.

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