- takes note of the Commission's decision not to propose a full ban on inducements, however, it welcomes the explicit Commission statements that there are potential conflicts of interest in the sales and distribution models for investment products, while standalone financial advice and financial planning services are largely unavailable to most consumers in the EU, and therefore most consumers only have access to advisors who advise on the products that they sell;
- points out that there is already an independent advice gap for consumers who are shying away from investing in financial markets as they would like to use investment products that provide a more stable investment return; proposes to extend the review period to three years of effective application to assess the results of market application;
- regrets that the complexity of products is increased by benchmarks and new warnings for "particularly risky investments" instead of more structural design-related measures; recommends that the idea of "basic products" such as basic bank accounts and compulsory motor vehicle liability insurance would apply to mainstream retail financial (investment) products;
- welcomes the Commission proposal to align ongoing training requirements under IDD to MiFID and codify the related European Securities and Markets Authority (ESMA) Guidelines, defining a minimum training requirement, including on sustainability, for sales intermediaries, which should be further expanded up to at least 35 hours per year;
- recommends providing guidance to product manufacturers on how to measure and disclose the actual sustainability impact instead of only green capital expenditure, as this is often how retail consumers interpret sustainability; recommends making sustainable products the default option through an opt-out rather than an opt-in;
- welcomes the Commission proposal to harmonise disclosure requirements; nevertheless, regrets that disclosure rules for insurance-based products remain subject to a different regime instead of being fully integrated into the PRIIPs framework; recommends that co-legislators build on the Commission proposal during the next legislative cycle and align all disclosure rules for insurance-based products to PRIIPs.
For more information, please contact the INT Section Secretariat