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Response to the EC Consultation on the recommendations of the Liikanen Group on reforming the structure of the EU banking sector

EuroFinuse agrees with the general recommendation of the Expert Group on the necessity of legal separation between risky financial activities from deposit-taking activities within a banking group. We agree as well that this separation should be aimed at protecting their socially most vital parts, which indeed are deposit-taking and those related to the provision of funding to the non-financial sectors of the economy. However, we consider that further consideration should be made on how this separation should be made. We doubt that the emphasis should be on separating the most volatile and risky part of the business from the retail part of banks. Instead we should focus on isolating the retail part of banking institutions and leave the rest of the activities outside the wall. This would reduce the incentives for the financial industry to lobby for keeping more risky or speculative parts of the business together with retail banking activities and consequently benefit from cheap funding for those activities that have no direct link with the real economy.

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EC Consultation on UCITS and long-term investment

The promotion of long-term investments is crucial in many ways: for the well being of EU citizens - representing current or future pensioners who have to rely increasingly on the performance of their long-term and pension savings - and for the development of the EU economy and subsequently the creation of jobs. This is why EuroFinuse believes the solutions for long-term investment envisaged by the European Commission consultation published on 26 July 2012 on “Undertakings for Collective Investment in Transferable Securities (UCITS) - Product Rules, Liquidity Management, Depositary, Money Market Funds, Long-term Investments” are insufficient to address the current situation. EuroFinuse therefore proposes in its response to the consultation measures that bear far greater impact.

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Reply to ESMA on its technical advice on possible delegated acts concerning the Prospectus Directive

EuroFinuse welcomes the consultation from ESMA on technical advice on acts concerning the Prospectus Directive. However, this is a very specific consultation concentrating on very legal matters. We would like ESMA to focus also on other key disclosure issues raised by the implementation of the Prospectus Directive and Regulation, in particular the very poor quality of the Summary Prospectuses, for debt securities as explained in more detail in EuroFinuse’s position papers on the PRIPs initiatives. We strongly regret the exclusion of securities from the scope of the PRIPs Regulation proposal, and we urge ESMA to ensure that the disclosure requirements for securities are at par with those for other “substitute” investment products accessible to individual investors.

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