Associazione delle Società per la Consulenza agli Investimenti
ASSORETI
ASSORETI is the Italian Association of Banks and Investment firms which provide investment advice service through their financial advisors authorized to act outside the intermediaries’ premises.
ID: 43106565215-92
Lobbying Activity
Response to Recommendation on savings and investment accounts
8 Jul 2025
Assoreti Association of intermediaries which provide investment advice service through their network of qualified financial advisors welcomes the European Commission initiative to develop a European blueprint for savings and investment accounts. At the present stage of the consultation, Assoreti would like to present the following considerations: 1. the investments performed through a saving and investment account should fall under the MiFID investor protection rules, including those related to the investment advice service; 2. without prejudice to the tax incentives, which are essential for the success of the initiative, the provision of any guarantees of result should be left to the choice of the individual intermediary who has the legal requirements to bear responsibilities at its own risk (insurance undertakings, banks and investment firms authorised to deal on their own account). For further information, please refer to the attached document. Assoreti wishes to thank you for the attention provided and is available for any collaboration requests.
Read full responseMeeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)
18 Jun 2025 · • SIU • Retail strategy
Response to Revision of EU rules on sustainable finance disclosure
30 May 2025
Assoreti Association of intermediaries which provide investment advice service through their network of qualified financial advisors is grateful to the European Commission for the opportunity given to hear its views on the Revision of EU rules on sustainable finance disclosure (SFDR). Actually, the framework has led to various application uncertainties for both manufacturers and distributors, leading the Authorities to start a review process and to intervene in fund naming. In this regard, we would like to represent the perspective of intermediaries that provide investment advice service. Any uncertainty regarding the sustainability framework may have negative impact on the fiduciary relationship that such intermediaries establish with their clients. Actually, for future regulations to be enforceable, the classification of what is sustainable and what makes sustainable products must be reasonably clear. Moreover, it is essential that all the different sustainability frameworks interact with one another; nevertheless, it is also essential that these frameworks communicate contextually with MiFID II and/or the other financial sectoral disciplines (IDD, CRD, Solvency, etc.). So far, this dialogue does not seem to have taken place properly. For instance, with regard to the regulation of investment services, the SFDR definitions do not communicate with the categories specified in art. 2 (1) (7), lett. a), b) and c) of the Commission Delegated Regulation (EU) 2017/565, which define the sustainability client preferences that the distributor must take into account when recommending investment products. As a result, it is essential that the sustainability frameworks be revised alongside the revision of MiFID II and the IDD, in order to ensure the necessary harmony between the definitions of sustainability and the criteria used by intermediaries to collect and assess investors sustainability preferences throughout the advisory process.
Read full responseResponse to Savings and Investments Union
7 Mar 2025
Assoreti is grateful to the European Commission for the opportunity given to hear its views on the Savings and Investment Union. Some summary considerations are given below. Please find in the attached position paper our specific remarks and proposals regarding the area of intervention. *.*.* Market regulation is intended to create a safe environment for investors, but we are seeing a significant gap between over-regulated markets and parallel, often illegal markets that are booming, particularly via the internet and social media. It is necessary to review regulatory policies by simplifying the regulation of regulated markets, while also providing additional resources and powers to competent supervisory authorities to prevent abuses for greater efficiency and investor protection. A simplified and integrated market requires the same regulation in member States and close coordination between NCAs and EU-Authorities to ensure uniform application. This is one of the objectives of the Saving and Investment Union. Part of this should be a tax incentive regulation, to be provided at the European level to encourage Member States to accomplish common economic and social policy goals uniformly. Simplification of the rules would lead to cost reduction for both firms (keeping compliance costs to a minimum) and investors (lowering the prices of products and services), contributing to boosting investment and supporting growth and competitiveness of the Europe. Simplification should be done wisely, removing inefficient rules and maintaining or, if necessary, implementing those that achieve effective protection of investors interests. The proposals made above should apply in general, not just to the simple and low-cost products for savings and investment indicated by the EC. In all cases, such products must be precisely identified and harmoniously governed under existing investment services legislation. In this regard, the investment advice service should be enhanced even in the offer of simple products, increasing investors financial knowledge and making them aware of investment choices. This approach may be a more effective way to direct savings towards healthy investments that support the EUs environmental and social policy goals. We support the Banking Union as a model that should remove all barriers to full harmonisation. In this regard, the primary goal should be the complete convergence of IDD towards MiFID II (already started within the preparatory work of the RIS). In fact, it aims to ensure the same level of protection to investors when subscribing to financial instruments and insurance or pension investment products, and to allow firms that distribute them to apply a certain and unitary set of rules.
Read full responseResponse to Retail Investment Package
7 Aug 2023
Assoreti Association of intermediaries which provide investment advice service through their network of qualified natural financial advisors is grateful to the European Commission for the opportunity given to hear its views on the Retail Investment Strategy. We support the Strategys overall goal of increasing retail participation in financial markets, achieving the same level of retail investor protection throughout the EU and across all investment products and distribution channels, and levelling MiFID and IDD frameworks. We support the Commissions proposal to phase in a partial restriction on inducements in execution-only contexts rather than imposing a complete ban. However, we believe that the proposals exemption for transactions recommended under the advice umbrella should be interpreted broadly, allowing inducements to be received for all transactions falling within the advice scope rather than just a single transaction resulting from a recommendation to buy a financial instrument. We also welcome the introduction of value for money principle. The introduction of quantitative benchmark, on the other hand, raises some concerns because it appears to be focused on the product, rather than on the service relationship with the clients, with the effect of undermining the core goal of the investment process. The best interest test, that links the recommendation to the products cost efficiency, without considering a comparative assessment of cost, performance and nature and quality of the service provided to clients, raises similar concerns for us. The aforementioned quantitative benchmark and the best interest test focused on costs product lower the quality of investment advising service, provided on a portfolio basis, and appear to be counter to investors best interest. We would like to emphasize that providing a simplified suitability test only for independent advice relating to well-diversified, non-complex, and cost-effective financial instruments appears to be inconsistent with the principle of equal treatment and market competition if it is not extended to non-independent advice and portfolio management. We advocate an equal treatment for the investment advice and portfolio management also relating the payment of inducements, as we do not understand why the proposal introduces a ban of these payments for the portfolio management. Lastly, we hope that the review clause will not be tied to the independent advices spread in the market, as all investment services are equal in value.
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