In the context of the CMU action plan, it is essential to ease retail investors’ access to financial markets while ensuring a high level of investor protection.
The EBF welcomes the opportunity to respond to ESMAs Call for
Evidence on the European Commission’s mandate on certain aspects
relating to retail investor protection.
- Review of information requirements and technology neutral approach
The EBF welcomes a review of the
information requirements since the current regime is too complex and not
calibrated to clients’ needs. We support easing requirements for
professional and eligible counterparties as well as knowledgeable retail
investors through changing opt-up criteria. We agree with ESMA it is
very important to ensure that the disclosure requirements are technology neutral so that it is easy for clients to understand and access the information also in an online environment.
- Horizontal alignment of requirements
Furthermore, there should be horizontal alignment between legislation to ensure transparency and comparability, especially uniform information for similar investment products and services.
Discrepancies in the sustainability
regime in MiFID II and SFDR should be addressednotably regarding
reporting frequency of individual portfolio management. There is also
great concerns relating to the overlapping implementation period of the
SFDR level 2 requirements (1 jan 2023) and MiFID II rules on suitability
assessment (3 aug and 22 nov 2022). The EBF strongly support postponing
the MiFID II level 2 requirements until 1 jan 2023.
The benefits of an open finance approach
in the field of retail investment will strongly depend on how an open
finance policy is implemented in the EU and whether the initiative is
limited to data that is now held by banks instead of all the data that
is useful in the financial ecosystem, including data from other sectors.
We would like to to underline that
disclosures do not automatically lead to increased investor protection.
Financial literacy remains a key feature to improve retail investors’
access to capital markets. x
EBF
© EBF
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