Side by side
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.
Industry association · Italy
Industry association · Germany
Declared costs: under €10K a year · in the register since 2009
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.
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.
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.
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.
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.
German Banking Industry Committee · filed 12 May 2021 · source
GBIC welcomes the opportunity to comment on the Commission’s roadmap: 1. Inducements A potential ban on inducements would run counter the roadmap’s explicit aim to raise the level of participation by retail investors in financial markets.
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.
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