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.
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.
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.
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.
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.
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.
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.
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