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Fédération Européenne des Conseils et Intermédiaires Financiers

FECIF

FECIF has been set up in 1999 to represent and defend the interest of the financial intermediaries in Europe.

Lobbying Activity

Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

21 Jul 2025

The Fédération Européenne des Conseils et Intermédiaires Financiers (FECIF) welcomes the focus put by the European Commission on addressing supplementary pensions with the intention to improve the financial security of households in old age. Demographic changes across Europe are putting a strain on pension systems in all countries, creating a growing pension gap threatening the long-term financial security of European households. The situation is different in each Member State however, as the architecture of pension systems, but also household savings and investments differ. Supplementary pensions can contribute to reducing the pension gap, by generating additional income in retirement. FECIF believes that such efforts can be successful if they address the whole lifecycle of pension investment. Firstly, it is important to increase participation and contribution, from an early age. Although very much debated, this is not the largest gap in the long-term savings challenge, as evidenced by the very high household savings rate across Europe. Initiatives such as the French PER product (created by the 2019 Loi Pacte) demonstrate that creating new savings products can be highly successful; auto-enrolment initiatives in the workplace have also proven effective. Secondly, it is useful to shift the allocation of long-term savings towards more productive investments, as clearly outlined in both e Draghi and the Letta reports, is even more important. FECIF estimates that as much as 15tn in household financial assets, put aside for retirement, are invested in short-term, liquid assets generating insufficient returns, due to a lack of advice and tight legal constraints. Thirdly, turning accumulated savings into supplementary income in retirement is an equally important step in improving the financial security of households, yet not much addressed by the debate so far. Here again, the variety of situations means that the solution needs to be tailored to each individual household. Financial advisors play a key role in helping households navigate the complexities of retirement planning, particularly in an environment where individuals are increasingly responsible for securing their own financial futures. As retirement savings shift away from state- and employer-driven models, advisors are essential in bridging knowledge gaps and offering personalized strategies to address diverse needs. FECIF believes that is absolutely vital that initiatives taken by the European Commission to strengthen supplementary pensions allow for personalised advice. The attached paper explores more in detail all the aforementioned aspects.
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

The European Federation of Financial Advisers and Financial Intermediaries (FECIF), representing over 300,000 financial professionals, 30 million clients, and 3 trillion in investable assets across the EU and EEA, welcomes the European Commissions consultation on the state of capital market integration and effective supervision in capital markets. We welcome the European Commission's initiative to enhance market integration and financial supervision within the European Union. A truly competitive and efficient financial ecosystem requires the removal of existing regulatory and fiscal barriers that hinder cross-border operations and financial mobility. To enable seamless operations for financial advisors and intermediaries, it is essential to implement more standardized rules that ensure a more harmonized fiscal and legislative environment. Excessive bureaucratic hurdles continue to prevent professionals from offering their services across borders, complicating the establishment of an integrated financial market. The current framework for passporting is overly restrictive, particularly for qualified financial advisors, whose ability to operate in other Member States is constrained by unnecessary complexity. Simplifying these procedures and allowing broader access to financial activities would significantly contribute to a stronger and more unified market. At the same time, whereas the Savings and Investments Union seeks to foster integration, scale and efficient supervision in the single market, the overall strategy does not address substantive tax issues, since the main point of the text focuses on actions for removing tax barriers and instead, much more shall be explored in this area to integrate capital markets. While large financial institutions play a crucial role in the global financial system, maintaining diversity in financial actorsespecially smaller advisory firmsis essential for ensuring competitive dynamism and innovation. A regulatory framework that supports the growth of smaller players while maintaining financial stability will foster a more efficient market. In this regard, a standardized tax treatment across Member States would significantly reduce inefficiencies and allow European markets to operate as a cohesive entity. Pan European investment products, such as PEPPs, are advisable, but they must be based on real incentives and should be without quantitative bumpers. Although effective supervision is necessary to ensure financial stability, an overly stringent regulatory framework disproportionately affects smaller actors. A proportional approach must be adopted to guarantee fairness in oversight while preventing unintended restrictions on market participation. Here, an active self-regulation by qualified professionals could be an outstanding support to regulatory simplification. Additionally, a lack of financial portability within the EU limits citizens' ability to efficiently manage their savings when relocating for work or personal reasons should be solved: we support financial portability with customer control over their data within an Open Finance framework. The creation of equivalent pension schemes and investment structures would allow for seamless financial transitions across borders, ensuring greater flexibility for individuals and businesses alike and to contribute then to financial markets integration as foreseen. We appreciate the European Commissions efforts in identifying these critical challenges and look forward to further discussions. Our sector remains fully committed to collaborating in studies and analyses that will contribute to pragmatic solutions. Financial advisors are and should be a key element in bringing closer the European savers to financial markets in the process to generate more investment for the European economy and better returns for their saving efforts; and to contribute to the most needed improvement of financial and investment education for European citizens.
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Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

The European Federation of Financial Advisers and Financial Intermediaries (FECIF), representing over 300,000 financial professionals, 30 million clients, and 3 trillion in investable assets across the EU and EEA, welcomes the European Commissions initiative to revise the Sustainable Finance Disclosure Regulation (SFDR). As the principal voice of Europes financial advisers and intermediaries, we remain committed to supporting the EUs sustainability agenda and to ensuring that the regulatory framework enabling it is effective, inclusive, and grounded in market realities. We welcome the Commissions intention to simplify and streamline the disclosure framework, clarify key concepts and obligations, reduce unnecessary regulatory duplication, and explore a more intelligible and practical categorisation of sustainable financial products. FECIF strongly supports these goals. We believe that the revision process offers an important opportunity to refocus the SFDR framework toward clarity, proportionality, and usability, especially for retail-facing professionals and the clients they serve. In this contribution, we offer practical recommendations to support a better-aligned, future-ready SFDR. We also propose ways to ensure that the advisers role is enhancednot underminedby reforms. Finally, we encourage the Commission to consider a forward-looking expansion of the SFDR to include biodiversity and natural capital disclosures, in a phased and proportionate manner. We strongly believe that well-informed, well-supported advisers are essential to the success of sustainable finance in Europe. They are the bridge between regulatory ambition and real-world investor behaviour. By simplifying and clarifying the SFDR, and by respecting the distinct roles within the investment value chain, the Commission can significantly enhance the credibility, usability, and impact of the framework. FECIF remains available to engage further with the Commission, European Supervisory Authorities, and other stakeholders as this revision proceeds.
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Response to Review of the Securitisation Framework

19 Mar 2025

FECIF, the European Federation of Financial Advisers and Financial Intermediaries, is pleased to present our contribution to the Call for Evidence on the review of the European securitisation framework. We appreciate the opportunity to provide input aimed at improving the efficiency and resilience of the securitisation market in Europe. We believe that a properly functioning securitisation market is essential to diversify funding sources, promote financial stability and support economic growth across the European Union. We also believe that financial advisors, given their role as a link between financial intermediaries and households, could significantly contribute to the achievement of the objectives of the Savings and Investments Union (SIU), including securitisation as a bridge between savings and investments. With this objective in mind, we would like to highlight some key observations and recommendations. FECIF believes that the scope of Regulation (EU) 2017/2402 (SECR) should be more clearly defined, applying it to any securitisation in which at least one of the parties involved is based or authorised in the EU. The definition of securitisation and originator should be extended to include any type of financial institution or institution created specifically to operate in the credit sector. Capital rules must be uniform for all innovative entities, so that AIFMs can maintain the risk envisaged by the SECR. At the same time, the momentum of financing alternatives to bank credit must be preserved, maintaining transparency and due diligence requirements for securitisation equivalent to those that exist for other sources of financing. We are in favour of free competition on equal terms. The FECIF also believes that the STS label can stimulate the growth of the securitisation market, but the lack of familiarity and recognition as a distributable instrument hinders the dissemination of the STS standard throughout the Union. To promote this dissemination, it is necessary to involve financial advisors, with reinforced training in securitisation. We encourage the European Commission to take these recommendations into account as part of its review process. A pragmatic and forward-looking approach to the securitisation framework based on transparency, and free and fair competition of financing models, will ensure its continued contribution to the EU's financial and economic priorities within the framework of SIU.
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Response to Savings and Investments Union

6 Mar 2025

FECIF, the European Federation of Financial Advisers and Financial Intermediaries, represents 450,000 European financial intermediaries through 24 national trade associations, operating across all EU member states, plus the UK and Switzerland. Chartered in June 1999, FECIF is the only European body representing European financial advisers and intermediaries. It works actively for the support and promotion of the role of financial advisers and intermediaries in Europe. FECIF appreciates the opportunity to provide input for the European Commission on the Savings and Investment Union (SIU), due to its central role in the Commissions policy agenda, as the institution itself has highlighted. At FECIF we believe that it has become imperative to find effective ways of channelling the savings of European citizens towards investments in the real economy, in particular in AIFs and innovative European start-ups, thus avoiding capital flight to non-EU countries. To achieve this overarching goal, we put forward the following suggestions, which we remain available to further discuss in detail. Firstly, we believe that tax leverage is the key to attracting investment to the EU, and that the SIU should take full account of future reforms in this policy area to boost the financial services sector, for example providing specific tax deductibility for certain investments. In our opinion, this leverage should be common and integrated into already defined and regulated instruments, such as ELTIFs, which could be given catchy names to attract a broader set of customers. Moreover, FECIF finds that there is a need to focus on investment products that prioritize the financing of European companies, while prompting issuers to create attractive savings products that can be distributed among investors, thus giving them the opportunity to earn a good return. Furthermore, we suggest that specific products could be developed for institutional investors and others for retail investors; for the latter, simple instruments with short to medium-term liquidity, e.g. even three years, could be envisaged. Finally, we are convinced that cross-border pension funds could be encouraged to invest in start-ups, private equity and venture capital. In our view these are four key areas that the SIU should tackle in order to achieve its goals of transforming private savings into more productive investments that can actually finance the economy and of supporting wider strategic EU objectives while expanding financing opportunities for businesses, particularly small and medium-sized enterprises.
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Response to Open finance framework

31 Oct 2023

On 28th June 2023, the European Commission presented a proposal for a regulation on an Open Finance Framework, with a view to enable consumer data sharing and third-party access in the financial sector, in light of the EU digital finance strategy. With this response to the consultation, the European Federation of Financial Advisers and Financial Intermediaries (FECIF) aims to present its comments on the proposal for a regulation on the Open Finance Framework (hereinafter, the FIDA proposal or FIDA). FECIF represents around 450,000 European financial intermediaries through 24 national trade associations, operating across all EU member states, plus the UK and Switzerland. As such, it is the only European body representing European financial advisers and intermediaries. FECIF recognizes the importance of data sharing in the financial landscape because data is a powerful tool for making informed investment and financial decisions. As the representative of Financial Intermediaries in the EU, FECIF understands the pivotal role of data sharing in the growingly digital financial sector. FECIF agrees with the overview presented in the Commissions Impact Assessment Report which accompanies the FIDA proposal, in particular with the problem definition, the identified problem drivers, and the resulting consequences for consumers and the financial market. It also agrees with the general and specific objectives of the FIDA proposal. Overall, it is clear that an EU-wide Open Finance Framework cannot be implemented without a specific regulation that lays the appropriate rules for it. At the same time, it remains to be seen which shape the Open Finance Framework will take among the set of possible options that was presented. The attached paper presents FECIFs viewpoint and preferred solutions to make the implementation of an Open Finance Framework more solid and efficient, as well as some suggestions on how the FIDA proposal can be improved. To do this, the document starts from the different options outlined by the European Commission in its Staff Working Document, looks at the choice made in the text of the FIDA proposal, and provides further comments on the future rules that are to be established. For our detailed position, please see the document attached.
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Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings

1 Sept 2023

On 13th June 2023, the European Commission presented a proposal for a regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, as part of its renewed sustainable finance strategy, which was launched in 2021. With this response to the consultation, the European Federation of Financial Advisers and Financial Intermediaries (FECIF) aims to present its comments on the proposed directive. FECIF represents around 450,000 European financial intermediaries through 24 national trade associations, operating across all EU member states, plus the UK and Switzerland. As such, it is the only European body representing European financial advisers and intermediaries. FECIF recognizes the growing importance of ESG in the financial landscape, especially because they are used to make informed investment and financing decisions. As the representative of Financial Intermediaries in the EU, FECIF understands the pivotal role that ESG ratings play in guiding sustainable investments. Therefore, our assessment of this proposal starts precisely from this viewpoint. FECIF commends the Commissions efforts to create a regulatory framework for ESG rating agencies, thereby standardizing ESG ratings, promoting trust and transparency, and discouraging those behaviours that may affect the credibility and trustworthiness of ESG ratings. In the attached position paper, FECIF addresses the positive aspects of this proposal, including the promotion of trust and transparency, the fact that it addresses market dysfunctions, and its benefit for consumers and investors. At the same time, FECIF notes that certain aspects of the proposed regulation might require additional attention. In particular, FECIF looks at the likely impact of the proposal on small ESG providers, its lack of harmonization regarding ESG rating methodologies, and the probable limitation of the pool of companies providing a rating service. In the attached position paper, FECIF also provides suggestions for creating balanced and efficient rules regarding the transparency and integrity of ESG rating activities. Firstly, FECIF would like to warn about the future implementation challenges linked to this proposal. Secondly, FECIF believes that a balancing act should be sought between the goal of enhancing transparency and the need to avoid overly prescriptive regulations. Thirdly, FECIF stresses that, given the global nature of financial markets, it is essential to ensure that the EU's approach aligns with global standards. Finally, FECIF would like to draw attention to the need of engaging with all stakeholders, especially during the implementation phase of the future rules. These are some of the main points that FECIF would like to make on this proposal. For our detailed position, please see the document attached.
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Response to Retail Investment Package

25 Aug 2023

On 24th May 2023, the European Commission presented a proposal for a directive on retail investor protection to encourage and support retail investors participation in capital markets. With this response to the consultation, the European Federation of Financial Advisers and Financial Intermediaries (FECIF) aims to present its comments on the proposed directive. FECIF represents around 450,000 European financial intermediaries through 24 national trade associations, operating across all EU member states, plus the UK and Switzerland. As such, it is the only European body representing European financial advisers and intermediaries. FECIF fully endorses the goals of the Retail Investment Strategy (RIS) and of this proposal because it shares the objective to provide common rules for the financial and insurance sectors and to offer the same safeguards to European citizens regardless of investment type. FECIF has always stated the necessity to set the maximum harmonization between disciplines and it welcomes the goal of removing inconsistencies and overlaps of information requirements, as well as of adapting provisions on regulatory disclosures that are fit for digital use. At the same time, FECIF believes that certain aspects of the proposed directive require more attention, and that more work can be done to improve the legal text regarding specific topics and issues. The proposal calls for simplifying the information made available for investors. Although FECIF supports this objective, at the same time it must warn about the complexities of digitizing the information provided to investors, and it stresses that organisational difficulties and heavy burdens and costs might arise for financial advisors and insurers who will need to comply with the future rules. Regarding the new provisions, addressing the risk of unbalanced or misleading marketing communications, FECIF supports the Commission's intentions to address marketing policies that emphasize benefits and minimize risks to clients, and to implement a tight control over influencers and social media. On inducements, FECIF welcomes the change of direction undertaken by the Commission, but it argues that the proposal should be further improved, especially on the proposed three-year review clause, the ban on inducements for execution-only transactions, and the overall relation between commissions and the positive role of financial advisory services, which often goes unnoticed. At the same time, FECIF recognizes the need to develop an efficient and competent market of financial advice, and it hopes that this will take place through discussion with all stakeholders instead of decisions imposed through legislation. With reference to the use of benchmarks under the value-for-money principle, FECIF stresses that costs are not the only means to evaluate an investment product. Instead, appropriate consideration should be made about the products correspondence to the real needs of the customer. FECIF is also concerned about the risk of hampering innovation and limiting competition among intermediaries. On professional qualifications for financial advisors, FECIF supports the Commissions attention to high professional standards and qualifications. Yet, since financial advisors already meet high professional standards via their training, further considerations can be made on the optimal phrasing for these provisions. Finally, as an overarching issue, FECIF stresses the need to avoid overregulation. Given that the Retail Investment package will add rules in an already complex and regulated sector, the probability of creating unnecessary burdens remains a concrete hazard. Overregulation would ultimately produce negative effects for both financial advisors and for retail investors, and these risks shall be carefully considered. These are some of the main points that FECIF would like to make on this proposal. For our detailed position, please see the document attached.
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Response to Retail Investment Package

31 May 2022

We welcome the Commission’s intention to strengthen consumer participation in the development of capital markets. However, we cannot confirm the reasons given which lead to a lack of consumer participation in the markets and the statement that a "weak reliability and quality of the investment advice provided" can be observed for the European market. It is the clients of bank-independent advisory companies and the advisors working for them who are already taking advantage of the opportunities of the capital market to a much greater extent and are using investment fund-based investment products as a suitable capital investment. For most of the European markets, reasons other than those named by the Commission are relevant, which lead to consumers not benefiting from the capital markets to a sufficient extent. An excessive guarantee level is demanded for state-subsidised old-age provision products, which blocks the providers from integrating higher proportional shareholdings in the stock markets into the products, which reduces the returns of the products. A misguided state subsidy policy has so far been ignored by the Commission. The perception that a suitability and appropriateness test is limited to individual products is incorrect in this form. Members of national trade associations organized within FEICF already offer their clients holistic advice that takes into account their complete life, income and asset situation. They take this holistic view of the client's situation into account when making investment recommendations. A change in this area does not unintentionally lead to the discontinuation of long-term savings processes, especially in the case of insurance investment products for old-age provision. In many countries voluntary market initiatives show that there is no need for further national and European legislative measures in the current situation. Especially in the area of insurance investment products, the trend towards a holistic recording of customer situations in the advisory processes prevails. It can be observed rather in the area of purely digital brokerage offers, which are apparently considered a suitable instrument by the Commission, that conclusion routes are being developed in which the suitability test is greatly shortened and the speed of the conclusion is in the foreground, whereby the thoroughness of the analysis of the customer situation and thus of consumer protection is pushed into the background. We do not see any added value for consumers in this. The suitability test for the brokerage of insurance investment products still differs from that for capital investment products. In the vast majority of cases, insurance investment products initiate a long-term savings process aimed at old-age provision, in which, in addition to the customer's investment objectives, further complex framework conditions have to be taken into account. An insurance investment product often has to provide a substantial part of the investor's urgently needed retirement income at a point in time far in the future as well as ensure the security of his dependents. Significant security components must be taken into account, which is not the case in this form, especially with short- and medium-term capital investments. There are significant differences based on the different basic orientation of the savings processes for insurance investment and capital investment products, which stand in the way of further harmonization of the suitability tests. We advocate retaining the current legal framework and continuing to monitor its development. This applies in light of the fact that, for the first time from August this year, the sustainability preferences of consumers are to be recorded in the advisory processes. Any changes to the current legal framework can only be considered once an evaluation has determined the effects on and the significance for consumers' investment behavior triggered by this change in the advisory process.
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Response to Digital Operational Resilience of Financial Services (DORFS) Act

2 Mar 2021

We agree with the general findings and the 4 main risks identified. The desire for “resilience” seems perfectly coherent. However, we are very concerned that the new constraints could be very complicated to apply for small businesses, which represent the vast majority of stakeholders. We wonder about the effects of a strategy which aims, among other things, to reduce the administrative burden weighing on financial institutions, while in the 4 main objectives defined, 3 consist of strengthening the constraint on these companies. The abandonment of the idea of a dedicated European authority, however understandable it may be, does not seem to us to cause the abandonment of the approval or certification of IT tools or "service providers". Otherwise, the smallest players will on the one hand remain dependent on the largest, but also easily criticised by any authority and beyond, not being able to identify by themselves the weaknesses of a system. This will risk creating the security breach that we are trying to avoid, since it has been shown to spread its effects very quickly and far beyond the infected actor. Blockchain technology and DLT are all subjects poorly mastered by the players, who must on the one hand encourage a clear involvement of the competent authorities, including the identification of suppliers and recommended models, and on the other hand, to better educate and provide dedicated information for professionals, rather than sanctions, at least during a period of adaptation. Finally, we note an inability to deal with a Member State-wide cybercrime case. It would therefore be appropriate to facilitate the access of an attacked company to competent and responsive police and magistrates, at least at Union level.
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Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

We support crypto-asset regulations that are no longer just at the Member State level, but at the Union level. Indeed, some Member States have already put in place precise rules, which are not necessarily compatible from one State to another, while others have not even started to adapt their legislation. The logic of a "digital" package of 3 Regulations and 1 Directive (MICA) designed according to the mechanics of that concerning Markets and Financial Instruments (MiFID) may also be suitable. Likewise, the distinction between 3 categories of crypto assets seems appropriate.: The first are assimilated to financial assets and governed by the MiFID Directive, which seems logical to us, although we would like it to be clarified that financial intermediaries and advisers are competent in the matter. The second are assimilated to electronic currencies and are governed by a specific older text, which again appears suitable, even if, again, it would seem desirable to us to specify who can advise on the matter. Finally, the third, which is covered by this proposed text, seems to us to be able to be distinguished from the first two categories and should be the subject of specific regulation. However, we wonder about the meaning and the derogatory operation of the “pilot regime” which would concern crypto assets of the last category and even on the attachment of certain types of assets to the third category which will in fact benefit from simplified rules. We note that assets quite comparable to those of the first 2 categories seem to belong to the third: e-MT (e-Money Tokens), stablecoins and Asset Referenced Tokens (ART). Should e-MT and stablecoins not be linked to the regulation of currencies and ART to that of financial assets? Anyway, whilst we are in favour of the involvement of ESMA and EBA in the approval of actors and their referencing at EU level, we would like to avoid that this leads to an automatic passport, without the right of scrutiny from the authorities of the States in which the actors will be active, even though it would be a “test” regime and without the involvement of consulting professionals. Otherwise, it seems to us that the 4 risks identified in the framework of the EU's Strategy for Data could not be fully avoided and investor protection would be extremely low. Finally, we welcome the announced desire for simplification. However, it would have seemed "simpler" to produce a single text which would have imposed itself and would have cancelled, or in fact completed, the parts of the other pre-existing texts, which dealt with the subjects concerned
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Response to Action Plan on the Capital Markets Union

4 Aug 2020

In view of the new challenges that the Capital Markets Union (CMU) is facing in relation to the green and digital transformation of our economy, it is important to re-think the role that capital markets can play in Europe’s economic integration and sustainable growth. The crisis due to the COVID-19 pandemic, and Brexit, has made the CMU even more urgent. Even these challenges impose a pressure, it is important that they do not alter the solid foundations of European regulation. In this context, the most recent reforms in the financial sector (MiFID II, IDD, MCD) are highlighting the major role of financial advisors. In particular, the European Union emphasises the relevance of financial planning and its contribution to the increasingly important fulfilment of ESG factors. Accordingly, FECIF considers that a well-developed CMU must strengthen and improve the access to high-quality professional advice. FECIF agrees with the stated reasons of the importance of the CMU. In addition, we would like to point out the following challenges: (i) To achieve greater diversity of financial products and intermediaries promoting increased suitability, comparability and accessibility of different investment products and diversified funding choices of European companies. (ii) To strengthen resilience and stability and to remove barriers for increased cross border capital flows, promoting the use of DLT technology and tokenization (instead of reviewing securitization) and digitalization in the financial sector, ensuring technological neutrality in line with the “same activity, same risk, same rules” and proportionality principles. (iii) To increase retail participation by promoting financial literacy and qualified advice (following MiFID II, IDD, MCD), enhancing the application of key rules such as product governance and appropriateness, and suitability assessment, to improve the reach of retail investors to retail investment products adapted to their profile, and paying specific attention to climate-related disclosures, so advisors understand the product from the point of view of the assessment of ESG factors. (iv) To exploit digitalization for reducing bureaucracy in regulatory compliance to foster the provision of cross-border financial services, achieve supervisory convergence and increase supervisory cooperation through existing tools and new SupTech tools. (v) To ensure that regulation contributes to level the playing field among providers of financial services, ensuring equal treatment ("same activity, same risk, same rules") to promote free creation of products through better regulation and harmonized supervision. The debate on whether inducement and level of cost are useful for financing service (except in the case of capital given to firms) don’t consider that, unlike previously, the cost of compliance is a core component of the total cost. The increase of cost pushes people to ask for a reduction of firms’ incomes, without considering that these firms are offering useful services, creating job opportunities and paying taxes. (vi) To enhance the digital provision of services in the context of FinTech within the framework of the CMU to facilitate mobility in Europe and provide cross-border services online, the importance of which has been demonstrated during the crisis due to COVID-19 pandemic. Provision of hybrid services should be promoted, particularly in robo advice, recognising the client’s right to human interaction (“face-to-face”). FECIF welcomes the European Commission’s initiative on CMU and congratulates the High Level Forum for its work on Capital Markets published in June 2020. We strongly support the approach stated in the Roadmap, which considers EU strategies on sustainable finance through the European Green Deal and the promotion of a more digital Europe, through the European Commission Digital Finance Strategy/Fintech Action Plan.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Aug 2018

FECIF agrees with the general aim of this proposal, i.e. the integration of ESG in disclosures to end-investors. In particular, we appreciate the integration of sustainability risks and sustainable investment objectives both in the decision-making processes by institutional investors and asset managers and in the advisory processes by financial advisors. In this regard we agree with the following provisions on disclosure: transparency of policies on the websites of manufacturers and distributors (Article 3), integration of pre-contractual disclosures (Article 4), information on the reference benchmark (Articles 5 and 6), periodical reports (Article 7). All these elements integrate and support, at a more general and preliminary level, the recent proposals by the European Commission aimed at amending the delegated acts under MiFID II and IDD to ensure that sustainability considerations are taken into account in the advisory process, both in customer profiling and subsequent product selection. The proposed Regulation also makes it possible to empower the key role played by financial advisors in promoting awareness of ESG considerations among citizens, thereby fostering financial education and responsible and informed investment decisions. This development is clearly necessary if we consider the growing market complexity – also with regard to ESG issues – and the resulting demand for information and training expressed by financial advisors as crucial competitive factors. The proposal for a Regulation, with its specific rules on transparency of the the designated index, can also improve the knowledge of reference benchmarks among financial advisors: whereas 75% of the financial advisors surveyed had at least a “sufficient knowledge” of sustainable products, only slightly more than 50% had some knowledge of the reference indexes. These results show that training of professionals in ESG is weak and often left to the personal choice and sensibility of each financial advisor. That is to say, a specific and structured training on ESG issues is still missing. This lack of training may create the risk that regulatory intervention in pre-contractual disclosures and suitable investment recommendations cannot be really effective, inasmuch as the level of knowledge and competence of the relevant staff is insufficient and inadequate. In conclusion, we believe that the proposal for a Regulation can promote ESG transparency and harmonize different regulatory frameworks across contiguous sectors, thereby developing sustainability benchmarks and making sustainable finance an effective component of the advisory process (Actions 4 and 5 of the Commission’s Action Plan Financing Sustainable Growth). Nevertheless, it is still necessary to invest on ESG information and training of financial professionals in order to achieve effective regulatory action.
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Response to Institutional investors' and asset managers' duties regarding sustainability

18 Jun 2018

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under IDD to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection. FECIF believes that, by means of taking ESG-factors into account when deciding upon capital allocation, the intended adjustment of investment practices will lead towards a more robust investment culture. Embracing “long-termism” as a guiding principle, and requiring financial firms and advisors to consider the socio-political impact of their decisions, should facilitate the departure from the flawed axiom of short-termism, boost resilient investment practices, and decrease the proneness of financial markets to unforeseen shocks. A more fine-grained approach to financial advice (a more comprehensive and in-depth form of assessment that takes ESG-preferences into account) has the potential to strengthen the bond between advisor and customer. By adding another dimension to the assessment process, advisors are given the chance to fully meet their customers’ expectations and take their preferences into account more comprehensively, eventually adding towards a lasting and trusting advisor-client relationship. It is, however, unclear form the consultation text which specific ESG-factors need to be taken into account when providing advice. While advisors are, due to their status as trained professionals, used to assess their clients risk tolerance and their ability to deal with potential financial loss, they are not typically trained in systematically analyzing the socio-political (i.e. legal, economic, or political) impact of the products distributed by them. In particular, we agree with the recital of the proposed Regulation with regard to the need to introduce questions in the suitability assessment to identify the customer’s ESG (Environmental, Social and Governance) investment objectives. Including questions on ESG considerations helps customers become aware of sustainable finance (which is, in turn, related to long term investment solutions). In this respect, financial advisors play a key role, also in the distribution of insurance-based investment products (IBIPs); by making customers aware of ESG considerations, financial advisors promote financial education and foster responsible and informed investment decisions. Thanks to a direct relationship with customers, built on mutual trust and transparency, financial advisors are, among all financial professionals, one of the most viable channels to detect and promote ESG preferences.
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Response to Institutional investors' and asset managers' duties regarding sustainability

18 Jun 2018

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under MiFID II to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection. FECIF believes that, by means of taking ESG-factors into account when deciding upon capital allocation, the intended adjustment of investment practices will lead towards a more robust investment culture. Embracing “long-termism” as a guiding principle and requiring financial firms and advisors to consider the socio-political impact of their decisions, should facilitate the departure from the flawed axiom of short-termism, boost resilient investment practices, and decrease the proneness of financial markets to unforeseen shocks. A more fine-grained approach to financial advice (here: a more comprehensive and in-depth form of assessment that takes ESG-preferences into account) has the potential to strengthen the bond between advisor and customer. By adding another dimension to the assessment-process advisors are given the chance to fully meet their customers’ expectations and take their preferences into account more comprehensively, eventually adding towards a lasting and trustful advisor-client-relationship. It is, however, unclear form the consultation text which specific ESG-factors need to be taken into account when providing advice. While advisors are, due to their status as trained professionals, used to assess their clients risk tolerance and their ability to deal with potential financial loss, they are not typically trained in systematically analysing the socio-political (i.e. legal, economic, or political) impact of the products distributed by them. In particular, we agree with the recital of the proposed Regulation with regard to the need to introduce questions in the suitability assessment to identify the customer’s ESG (Environmental, Social and Governance) investment objectives. Including questions on ESG considerations helps investors become aware of sustainable finance (which is, in turn, related to long term investment solutions). In this respect, financial advisors play a key role: by making investors aware of ESG considerations, financial advisors promote financial education and foster responsible and informed investment decisions. Thanks to a direct relationship with investors, built on mutual trust and transparency, financial advisors are, among all financial professionals, one of the most viable channel to detect and promote ESG preferences.
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Response to Directive on cross-border distribution of investment funds

7 May 2018

The main purpose of the proposed texts is obviously focused on the way for Europe to create a true IF Market, leading to less costs for consumers and less numerous but bigger funds, proposed by a decreasing number of Producers, having capacity for cross-bording. The European Commission (EC) is expecting more marketing at a European level, considering only 30% of IFs (mostly UCITS) are proposed in more than 3 Member States. The EC is also expecting more technical and numerical systems because of the size these producers would be able to pay and run with. The EC is actually expecting increased employment, although the reason for that is not entirely clear, especially as numerous producers are actually SMEs that have created employment. We can definitely understand that Big is preferred to “Boutiques” and SMEs. That could be a concern for FECIF and its members. In order to achieve the defined goal, the EC proposes a strong action on regulatory fees; FECIF is in agreement with this. It could be done through transparency, predefined costs, a more simple system (numerical) and in banning some burdensome pre-communication to theESAs. The ESAs may also be obliged to answer more quickly to producers’ demands, especially if they are not national and send to ESMA their framework and prices/tariffs/costs which would be much more defined at a European level. FECIF would be in agreement to that sort of proposition. The difference between UCITS and AIFM Funds needs to be remembered but, for AIFM funds, the answer may be quicker and not based essentially on the advertising/marketing analysis (which seems to be the case at present). In some Member States, local facilities or stable establishment seems to be the principle. This would disappear and FECIF would support that. Perhaps of less interest but still helpful, is the proposition for a simplification of the updating procedure for documents and for a withdrawal from a national market. Technically, the EC is offering a solution by improving or writing 8 articles in the Directive (2009/65/EC) and in the AIFMD. If for 3 of these, questions could be raised, we can mostly be in agreement with the proposition. For information only, the 3 articles are: Article 77 Directive 2009/65/EC would be deleted, this would probably lead to the fact that the ESAs may not continue to be allowed to give advice on local distribution, but it is still not clear regarding the difference in the declared goal between AIFM funds and UCITS. Article 91(3) Directive 2009/65/EC would also be deleted. It appears the EC would in fact delete an obligation for producers aiming to enter into another market to insure an electronic distribution, with some dedicated constraints. Apparently, the new rules would only lead to a new system, which may permit local distribution if the producer makes sure that the fund is compliant with the local legislation and marketing requirements. New: AIFMD Article 30a is proposed, permitting a real test on professional investors when a producer would consider proposing a fund in another Member State. Regulatory part of the project: ESMA would become the leader and the main actor for Cross Bord-ng, becoming in charge of frameworks and also a central database, permitting access to an online register for national laws, marketing rules, and costs. ESMA would also produce some guidelines and develop an implementing technical standard on forms, templates and procedures. The delay for application would be 60 months.
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Response to Reducing barriers to cross-border distribution of investment funds

7 May 2018

The main purpose of the proposed texts is obviously focused on the way for Europe to create a true IF Market, leading to less costs for consumers and less numerous but bigger funds, proposed by a decreasing number of Producers, having capacity for cross-bording. The European Commission (EC) is expecting more marketing at a European level, considering only 30% of IFs (mostly UCITS) are proposed in more than 3 Member States. The EC is also expecting more technical and numerical systems because of the size these producers would be able to pay and run with. The EC is actually expecting increased employment, although the reason for that is not entirely clear, especially as numerous producers are actually SMEs that have created employment. We can definitely understand that Big is preferred to “Boutiques” and SMEs. That could be a concern for FECIF and its members. In order to achieve the defined goal, the EC proposes a strong action on regulatory fees; FECIF is in agreement with this. It could be done through transparency, predefined costs, a more simple system (numerical) and in banning some burdensome pre-communication to theESAs. The ESAs may also be obliged to answer more quickly to producers’ demands, especially if they are not national and send to ESMA their framework and prices/tariffs/costs which would be much more defined at a European level. FECIF would be in agreement to that sort of proposition. The difference between UCITS and AIFM Funds needs to be remembered but, for AIFM funds, the answer may be quicker and not based essentially on the advertising/marketing analysis (which seems to be the case at present). In some Member States, local facilities or stable establishment seems to be the principle. This would disappear and FECIF would support that. Perhaps of less interest but still helpful, is the proposition for a simplification of the updating procedure for documents and for a withdrawal from a national market. Technically, the EC is offering a solution by improving or writing 8 articles in the Directive (2009/65/EC) and in the AIFMD. If for 3 of these, questions could be raised, we can mostly be in agreement with the proposition. For information only, the 3 articles are: Article 77 Directive 2009/65/EC would be deleted, this would probably lead to the fact that the ESAs may not continue to be allowed to give advice on local distribution, but it is still not clear regarding the difference in the declared goal between AIFM funds and UCITS. Article 91(3) Directive 2009/65/EC would also be deleted. It appears the EC would in fact delete an obligation for producers aiming to enter into another market to insure an electronic distribution, with some dedicated constraints. Apparently, the new rules would only lead to a new system, which may permit local distribution if the producer makes sure that the fund is compliant with the local legislation and marketing requirements. New: AIFMD Article 30a is proposed, permitting a real test on professional investors when a producer would consider proposing a fund in another Member State. Regulatory part of the project: ESMA would become the leader and the main actor for Cross Bord-ng, becoming in charge of frameworks and also a central database, permitting access to an online register for national laws, marketing rules, and costs. ESMA would also produce some guidelines and develop an implementing technical standard on forms, templates and procedures. The delay for application would be 60 months.
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Response to Legislative proposal for an EU framework on crowd and peer to peer finance

7 May 2018

The terms “Crowdinvesting” and “Crowdfunding” are often used interchangeably in the media, and although Crowdinvesting and Crowdfunding are related forms of finance for startups, they are very different in some respects. Crowdinvesting means that users invest in a startup and receive shares in return. The investors become shareholders in the startup and benefit from the profits of the startups and if the startup is sold to a major investor (known as “exit”). Crowd investors are driven by a series of motivations. Some people simply want to support a good idea and their creators in its realisation, while other micro-investors focus on financial aspects, especially participation in a corporate sale. Crowdinvesting allows individuals to participate in startups with small (or larger) amounts. Crowdfunding is (still) better known as Crowdinvesting. This is simply because this phenomenon has been around for some time. Crowdfunding brings people together to finance a specific, mostly charitable or artistic project that would probably not have been realised without this funding. If there is something in return for Crowdfunding, it is non-monetary. Crowdfunding can thus be compared to a kind of donation. People help other people to implement a project; their motivation is altruism. For example, from the early 2000s, fans of popular music bands could support their artists via Crowdfunding and in return received CDs or access to exclusive concerts. For the purposes of this Regulation, ‘Crowdfunding service’ means “the matching of business funding interest of investors and project owners through the use of a Crowdfunding platform … which consist of the facilitation of granting of loans or the placing of transferable securities issued by project owners and the reception and transmission of client orders with regard to those transferable securities.” It is obvious that “investment” is in focus thus the term “Crowdfunding” would be misleading and should either be replaced by “Crowdinvesting” or extended by “Crowdinvesting and Crowdfunding”.
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Response to Review of the European Supervisory Authorities

21 Dec 2017

The “Fédération Européenne des Conseils et Intermédiaires Financiers” (FECIF) welcomes the proposals. However, we would firstly like to make some general comments: 1. The initiative is very timely at a moment when election in Member State sees a growing number of populist votes, driven not only by local issues, but mainly by an anti-EU feeling largely created by over-regulation. 2. It is important to take into account that more regulation means more costs for consumers (60% additional costs since the creation of the ESAs), increased administrative burden and may lead to less competitiveness on the global scene. 3. Most of the regulation has been made in the name of consumer protection but apparently the ESAs have in some cases missed the target, as consumers groups (such as “Better Finance”) are complaining about unnecessary regulation, leading to lack of efficiency. 4. Gold platting and national protectionism are the rule and not the exception, which means that the single Capital Market simply does not produce what was expected of it. 5. Over-regulation prevents the development of innovation: successful innovations were first unregulated (crowdfunding, FinTech, RoboAdvisor) and in some cases are still running outside of any kind of rule As a matter of conclusion, only an enhanced implementation of REFIT can improve the image of the EU in the eyes of the Europeans and reduce the EU regulation to a level that is efficient and understandable for both actors and consumers/investors Analysis: • Stronger coordination of supervision across the EU. The ESAs should set EU-wide supervisory priorities after a democratic consultation, check the consistency of the work programmes of individual supervisory authorities with EU priorities, and review their implementation. They should monitor authorities' practices in allowing market players - such as banks, fund managers and investment firms - to delegate and outsource business functions with a minimum level of restriction. • Improved governance and funding of the ESAs. The ESAs should take decisions more independently from national interests. We are favourable to the newly-created Executive Boards with permanent members who may be representatives of the stakeholders democratically elected, this could lead to quicker, more streamlined and EU-oriented decisions. Moreover, interested parties should be able to ask the Commission to intervene if the majority consider that the ESAs have exceeded their competences when issuing guidelines or recommendations. The EU budget should secure the ESAs' funding without any funding by contributions from the financial sector, which is already financing the NCAs. • Extended direct capital markets supervision by ESMA. We are mostly in favour of increased functions delegated to ESAs. However, The EC should not propose to make ESMA the direct and/or single supervisor over certain sectors of the capital markets across the EU: o Capital market data: ESMA should not solely authorise and supervise the EU's critical benchmarks o Capital market entry: ESMA should not be in charge of approving EU prospectuses, but be in charge of unified clear frameworks for those prospectuses. Prospectuses are documents that contain the information an investor needs before making a decision whether to invest in a company and the responsibility over the content should exclusively lie with the promoter and be done under the NCAs’ control if necessary. o Capital market actors: ESMA should not authorise and supervise investment funds to prevent restriction of the aim of creating a genuine single market for funds. Regarding Market abuse cases: we agree at FECIF that ESMA must have a greater role in coordinating market abuse investigations with the right to act where transactions or behaviours give rise to well-founded suspicions of cross-border implications or effects, for the integrity of financial markets and financial stability in the EU.
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Response to Proposal for a Regulation - Financial Stability, Financial Services and Capital Markets Union

25 Sept 2017

FECIF, the European Federation of Financial Advisers and Intermediaries, welcomes the European Commission’s initiative on the Pan European Personal Pension products (PEPP). This initiative contributes to the Capital Market Union and will help offer a simple and useful way for European citizens to save money towards retirement, addressing needs in countries where no second pillar exists as well as other jurisdictions given the potentially wide range of available solutions. FECIF believes that consumers will be able to make superior choices with better investment choices and features. Moreover it is essential that the PEPP makes professional and regulated advice a cornerstone of the distribution model and does not deprive consumers of access to it, when they are making crucial decisions regarding their pension savings. FECIF highlights, however, that the PEPP draft regulation still lacks details. Among other things, it is keen to ensure that the comparison of products must safeguard and respect local criteria but does not block competition. It also points out that the question of capital guarantees needs clarifying. On the whole, FECIF supports the open rather than prescriptive approach taken by the European Commission. In the context of a complex need, and a need that varies across countries (at least because of differences in the pension systems in place today), setting up rigid prescriptive rules would probably be counterproductive. However, left to their own device, there is a significant risk that local regulators will stick to existing local PPPs, reducing the positive impact of PEPP regulation. FECIF confirms that it is willing to continue contributing to this PEPP initiative wherever possible and relevant, helping adapt it to local market needs and expectations. It will, as ever, work together with regulators, industry representatives, consumer groups and all other stakeholders, to improve the choices available for savers and investors.
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Response to DA on product oversight and governance requirements for insurance undertakings and insurance distributors

4 Aug 2017

FECIF appreciate that the proposal of the European Commission is consistent with the text of the IDD directive. There is neither "gold-plating" nor weakening of the underlying regulation for insurance distribution. The identification of the target market is understood at a general and abstract level and does not overrule the demands and needs test with the prospective client. The POG obligations (article 1) lack an explanation of what is a "significant adaptation" - indexing, changing coverage (to what extent), changing cost structure (to what extent)? It would help in daily routine if there was, at least, a non-exhaustive list of what is meant by the EU Commission. We agree with Article 3, par. 3: the activities relating to the personalisation and adaptation of existing insurance products in the course of insurance distribution activities to the individual customer, indeed cannot be considered as activities of manufacturing. Manufacturers need a product approval process (article 4) with measures for corrective action for insurance products that are detrimental to customers. What exactly is "detrimental" - a rise of premiums, a decrease of coverage and to what extent? It would help in daily routine if there was, at least, a non-exhaustive list of what is meant to be detrimental by the EU Commission. Article 5 strikes a good balance with corresponding MiFID II requirements. Particularly, we appreciate the inclusion of a requirement which cannot be explicitly found in MiFID II: “When assessing whether an insurance product is compatible with a target market, manufacturers shall take into account the level of information available to the customers belonging to that target market and their financial literacy”. Nonetheless, we believe it is necessary to add a provision consistent with the one pursuant to Article 9, par. 12, MiFID II Delegated Directive (n. 593/2017). Please see the attachment. Product monitoring and testing (article 7, 3) stipulates that if manufacturers become aware of any circumstances that "may" adversely affect the customer of a product they shall take appropriate action to mitigate the situation and prevent further occurrences of the detrimental event. This wording would cause problems. Example: A customer bought an equity linked life insurance with share funds as underlying investments. The share markets go down for whatever reason. This "may" adversely affect the customer but, at the time of the incidence it is not said that this will happen. Following the current text of the delegated act the manufacturer has no other choice than “to prevent further occurrences of the detrimental event” which means f.e. to switch into safe assets by therefore materializing the loss although the share portfolio would maybe have recovered during the life-cycle of the product, anyway. We therefore ask for a slightly change of the text of par. 3, please see the attachment. With regards to Article 10 we ask to amend a provision to clarify the knowledge and competence of staff of insurance intermediaries. Please see the attachment.
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Response to DA on conduct of business rules for the distribution of insurance-based investment products

4 Aug 2017

FECIF appreciates that the proposal for the Delegated Act is consistent with the text of the IDD. To combine the three empowerments on additional conduct of business requirements for IBIPs into one delegated act is a clever move by the Commission and will make it easier for our members, the European financial advisers and intermediaries, to work with this regulation. We fully support article 3 of the of the introduction (page 5) which stipulates that it should not be sufficient that the insurance intermediary or the insurance undertaking may realise a benefit if this does not result specifically in a detrimental impact for the customer. The definition of relevant persons (article 2) is as well practicable as helpful to identify who is made responsible for taking care of the provisions of the delegated act. With regards to the criteria to assess whether an inducement or inducement scheme has a detrimental impact on the quality of the service to the customer (art.8, par. 3), please see our comments in the attached file. We agree with the information to be obtained for the purposes of the assessment of suitability, as they are aligned with MiFID II. With regards to art. 9, par. 4, we ask for an amendment regarding the specific type and amount of information. Our members do have a serious problem with article 9, paragraph 7: It states, that in case of a switch the intermediaries have at first to reasonably demonstrate that the benefits of switching are greater than the costs. The benefits of any switch show ex-post, the decision to make a switch is ex-ante. No intermediary can foresee the future to "guarantee" a client that his/her switch will outweigh the costs of the transaction by the future performance of the new underlying asset. If the text would remain as it is any client would have the right to claim backwards that the recommendation of a switch was not appropriate if the outcome of the switch proved him/her wrong. We therefore ask to for a slightly different wording in the text of article 9 par. 7. Considering the innate variability of returns, risks and costs of IBIPs, execution-only sales shall not be allowed. The investor should be provided with, at least, the assessment of appropriateness. We are missing regulation of automated sales under the "appropriateness" regime. While article 12 stipulates, that the intermediary´s responsibility to perform the suitability assessment shall not be reduced due to the fact, that advice is provided in whole or part through an automated system the analogous provision is missing in the section about assessment of appropriateness (this is the case in the delegated regulation for MiFID-2, too!). Results would neither be practice-oriented nor in the interest of consumers. In fact, online-sales of IBIPs (Fin-Techs, Insure-Techs) is mainly offered under the “appropriateness” regime. Therefore, it is crucial to insert an article 17 in section 2 (by consequently changing the consecutive numbering of the following articles). While we acknowledge the difference in the wording of the first-level provisions between the IDD and MiFID II directives, we restate that this problem of regulatory inconsistency needs to be resolved by a level playing field between the financial and insurance sector. Still, MIFID II sets a higher standard of quality for the investors, because inducements are required to enhance the quality of the service to the client (Article 11, Commission Delegated Directive 593/2017 and corresponding conditions). With regards to the criteria to assess whether an inducement or inducement scheme has a detrimental impact on the quality of the service to the customer, please see our comments in the attached file. We do not agree with Article 18, par. 3, i.e. the periodic report shall be provided at least annually: this provision would create an inconsistency with Article 60, par. 3, MiFID II delegated Regulation (n. 2017/565).
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Response to Reducing barriers to cross-border distribution of investment funds

19 Jul 2017

It is worth stating from the outset of this report that the European Commission’s effort to create within the European Union (EU) a Capital Markets Union (CMU) must be backed and supported by all parties involved in this sector. Many of the barriers have been removed by the European Markets Infrastructure Regulation (EMIR), Central Securities Depositaries Regulation (CSDR) and MiFID II however; plenty of more positive steps must be taken for the creation of a unified capital markets industry. Having said that, we believe that following Brexit, the need and necessity to modernise and clarify this overly regulated and in some instances unnecessarily, complicated sector is greater than ever. Cross-border competition and efficiency must be introduced and the only way to achieve that is by deregulating national barriers and introducing harmonised rules across all Member States. We strongly believe and assert that the underlying purpose of this initiative must specifically be to abolish national barriers (proven to prohibit and limit the cross boarder distribution of funds) and at the same time to provide investors a broader set of financial instruments in order to allow the expansion and growth of the funds market. This latter observation was also identified within the mid-term review of the capital markets union action plan where it was also acknowledged that the distribution of funds remains geographically limited. Sadly, and as it also stated within the Assessment, fragmentation, combined together with the uncertainty of different legislative obstacles mainly at a national level of the Member States restricts to a large extend the marketing of funds. Removing barriers mainly at national level and clarifying definitions to have same interpretation across all Member States are the key elements for the facilitation of the cross boarder distribution of funds outside of their domicile member states. We fully agree and support this initiative however, what we must avoid and be very careful of, is the introduction of further regulations, rules and procedures which we are sure will positively contribute towards the creation of an even further incomprehensible framework more bureaucratic in nature and consequently unattractive to potential investors. Decisions must be directed towards the creation of a CMU, whereby all parties involved in this market are clearly defined, roles and responsibilities are adequately, evenly and realistically distributed and barriers which prevent and/or have a material impact on the cross boarder distribution of funds are reduced and/or abolished. Also what is essential to note is that that barriers must not be seen in isolation. The main issue which the European Commission needs to identify and tackle is how barriers imposed both at a national and European level interact with each other creating a spider’s network full of fees and expenses for potential investors and an unnecessary burden upon Fund Manufactures/Manages We can foresee that the immediate aftermath of a unified and cohesive EU is going to be financial growth and stability, elements which are going to be put to the test at the post Brexit area. Furthermore, more substantive competition is going to be introduced across all Member States, which will invariably create the necessary conditions for the overall improvement of quality of services within the capital markets sector and consequently lead to the reduction of unnecessary fees, expenses and encumbrances.
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