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Draft proposal for Report on Good Practices for Disclosure and Selling of Variable Annuities

We consider that Variable Annuities (VA) products should be classified as PRIPs as should be all other more “traditional” classical and with profit life insurance products. There should be no difference of treatment or disclosure between those products which are purchased for investment or retirement purposes. We consider EIOPA’s recommendations for VA products concerning products features, costs transparency, level of products charges, selling practice and intermediary due diligence, apply also to the other traditional life and annuities products. It is very important that these products are sold only on an independent advise basis and that the inherent risks of these products if any be very clearly stated.

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Advice on the review of IORP Directive

We fully support the position of the GCAE, emphasizing the necessity of correct, understandable and non misleading information about pensions. “Communication with the members should also explain in simple and clear terms the principal risks implicit in the financial arrangements, how they are managed and the potential consequences of failure. Better communication regarding the purchasing power of the benefits is essential and should, in our opinion, be an important factor in disclosure.” Moreover, transparency in communication with all stakeholders should be encouraged, leading to better understanding of the complexities and risks in pension schemes. We agree with EIOPA that a new KIID-like document should be introduced and extended with information on contribution arrangements, practical information and cross references to other document.

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Guillaume Prache

Advice on ESMA’s public consultation on UCITS Exchange-tradedfunds in the European Union

We generally agree with the concerns raised by ESMA relating to the increased complexity of ETFs, that raise significant issues both with respect to investor protection and systemic risk. ETFs are a low cost and straightforward investment proposition for investors, and as such, ESMA should investigate how to make indexed ETFs more appealing to retail investors. In respect to the prevention and mitigation of the risks that may arise from ETFswe believe that, in addition to disclosure requirements, regulators should adopt a more interventionist approach. We also believe it necessary to avoid any type of regulatory arbitrage, by subjecting all UCITS products and exchange-traded products to similar rules.

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Guillaume Prache


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Wednesday, 05. December 2018