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Finance Denmark acknowledge that it is evident that there has been a decline in research coverage for small and mid-cap companies, but we do not believe that rolling back the unbundling regime is not the right way to solve this chal-lenge. We see issuer sponsored research as a much better tool to solve this chal-lenge.

CFA Institute welcomes the opportunity to provide its views on the proposed changes to the investment research rules under the MiFID II regulatory framework. CFA Institute has some reservation about the generalized relaxation approach and, in particular, the proposal of exempting unbundling of investment research for small and medium caps, including fixed-income research.

Currently, investor protection rules are set out in a number of sector specific legislative instruments at EU level, while general consumer protection frameworks remain under national rules. In order to better reflect the variety of issues across member states, it would be useful to target especially retail investors responses to the consultation. Could this be done through the traditional consultation process?

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.