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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.

I. Digital communication support The Czech Insurtech Association would like to express support for the European Commission's proposal regarding the prioritization of digital communication with customers within the framework of the Retail Investment Package.

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.

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.

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.

I. General support to the initiative On behalf of the Czech Insurtech Association, we would like to express our strong support for the proposed Open Finance Framework (FIDA) and, specifically, the development of an Open Insurance Framework.

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.

The Czech Insurtech Association would like to express gratitude for the Proposal on the Artificial Intelligence Liability Directive (AILD), which is the horizontal regulation with an impact on certain technology without consideration of sector specificities.

The German Banking Industry Committe (Die Deutsche Kreditwirtschaft) welcomes the opportunity to provide feedback to the European Commissions inception impact assessment on adapting liability rules to the digital age and artificial intelligence. Please find our detailed position on this initiative in the attached document.