Association Française des Produits d'investissement de Détail et de Bourse
AFPDB
The AFPDB (French association of the structured and listed retail investment products) represents the interests of the main issuers of structured products that distributed in France.
ID: 025380938176-48
Lobbying Activity
Response to Recommendation on savings and investment accounts
7 Jul 2025
Please find hereafter attached the AFPBD's answer to this CfE
Read full responseResponse to Savings and Investments Union
3 Mar 2025
AFPDB welcomes the objective to mobilize European savings more effectively. We believe that 5 points of attention need to be made: 1. Attractiveness of investment products implies a simplification of the investors journey and not to burden any further the regulatory framework. AFPDB believes that simplification and streamlining of regulatory objectives should be the way going forward. There are too many gold-plating rules or practices while an efficient European regime relies on a harmonized framework and supervision as well as industry-led best practices. 2. The simplicity feature of investment products should be more carefully assessed as there are several angles to it and ensure a level playing field among asset classes. Simplicity does not equate to low-risk. Both features should also be linked to return and performance of products. Simplicity is obviously an asset from a retail investor's perspective. However, it is no substitute to a proper risk-assessment. Very simple products can be very risky, while features adding to complexity often protect investors (such as capital protection) making products less risky. Its also important to make sure that any simplicity/complexity screening of products is consistent among all asset classes, to ensure an appropriate level-playing field and to the ultimate benefit of retail investors. 3. Low-cost does not necessarily mean good quality of investment or services. Instead, retail investment products should deliver value for money. 4. The wider spectrum of products should be considered. Thinking otherwise would be detrimental to the diversification of savings, as well as financial innovation. Structured products have key features that make them suited for privileged savings schemes. Indeed, to promote European investment product, retail investors should be provided with a wider range of products and investment solutions spanning all asset-classes or wrapper types. In that perspective, there are key arguments for considering structured products as eligible assets for tax- or otherwise privileged long-term investment schemes: - Structured products mitigate risk. With investment solutions ranging from full exposure to fully capital-protected instruments, they may fit any investment objective and risk tolerance. - Structured products can provide diversification of investment, through an exposure to multiple asset classes, strategies, or risk factors in a single instrument. - Structured products deliver a foreseeable yield under a fixed, predefined, market scenario. Many structured products have a fixed-coupon and full or partial capital-protection, allowing to forecast a certain return level. - Structured products can serve as cost-effective investment instruments. They generally do not have recurring (performance) fees. Instead, costs are often embedded in the initial structuring of the product making them predictable and transparent investment option. All of the above features make them able to meet specific retail investment needs and objectives of retail investors as well as a compelling addition to privileged long-term savings and pension schemes. 5. Taxation is a core driver and must be open to all European asset-classes of retail investment products to avoid market distortions.
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