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Izba Domów Maklerskich

IDM

The Polish Chamber of Brokerage Houses as an advocate for the interests of capital market participants The mission of the Polish Chamber of Brokerage Houses is to support the development of a competitive capital market that offers conducive conditions for companies to source capital for investment purposes for economic growth and building the wealth of citizens. The Chamber acts as a Capital Market Advocate - presenting recommendations and opinions to the public that affect the attractiveness and efficiency of the capital market, as well as expresses opposition to practices or solutions considered harmful to the development of the capital market and the economy. The Chamber actively cooperates with self-governing organizations of financial market circles in Poland and abroad to develop joint positions and expert opinions on issues relevant to the capital market. The Polish Chamber of Brokerage Houses as a self-regulatory and co-regulatory institution for the brokerage community The fou

Lobbying Activity

Response to Retail Investment Package

28 Aug 2023

Key points We are opposed to any changes to existing incentive rules. When implementing the Strategy, it should be borne in mind that the regulatory framework should enable the coexistence of various business models existing in individual EU countries. The idea of establishing EU central benchmarks is damaging to smaller capital markets. It is important that the Strategy takes into account the fact that in individual Member States the profile of retail clients differs in terms of wealth, financial and technological knowledge, as well as the level of participation in capital markets. General comments IDM welcomes the European Commission's proposal concerning retail investors ("Strategy") aimed at strengthening the participation of retail investors in the development of capital markets. We share the Commission's view that consumers who invest in capital markets should have certainty and trust that their investment performance will improve, which in turn will lead to an increase in the share of retail investors in investments. The increase in investments of individual investors in capital markets, who will direct their capital to companies from the private sector, will help in the process of economic recovery after the negative economic effects of the COVID-19 pandemic. According to IDM, it is extremely important when implementing the Strategy to ensure that the regulatory framework allows for the coexistence of different business models existing in individual EU countries. In our view, a regulatory framework based on a one-size-fits-all approach will not create a competitive and efficient EU capital market, especially given the existing diversity of business models. In addition, it should be borne in mind that the profile of retail clients varies across Member States in terms of wealth, financial and technological knowledge, as well as the level of participation in capital markets. We would like to point out that the proposal to introduce some of the provisions of the Strategy involves the investment firms having to incur significant financial outlays. In our opinion, the Strategy should be thoroughly analysed both in terms of incurring additional costs (budget for investment companies to meet additional, new requirements) and forcing changes in IT systems (deep interference in the technological environment), legal documentation (modification of contracts, procedures and regulations). In connection with the above, we propose a significant extension of the planned date of its entry into force, drawing attention to the fact that the market has not yet dealt with the implementation of changes related to ESG, and the proposed Strategy additionally makes it difficult for investors to find their way in the complex regulatory structure of MiFID II.
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