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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.

ASC
Ascofind

Industry association · Italy

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
FD
Finance Denmark

Industry association · Denmark

29
files engaged
of 583 tracked
34
positions filed
in those 583 files
10
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1.8M+ a year · in the register since 2012

Files both filed on (2)

Retail investor protection rules · Retail Investment Strategy

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

Ascofind · filed 26 Aug 2023 · source

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.

Finance Denmark · filed 28 Aug 2023 · source

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.

Retail Investment Strategy

Ascofind · filed 17 May 2021 · source

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.

Finance Denmark · filed 18 May 2021 · source

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.

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