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The document serves as BETTER FINANCE response to selected questions of ESMA’s discussion paper on the implications of digitalisation for investor protection under MiFID II. The document “Discussion Paper on MiFID II investor protection topics linked to digitalisation” provided by the European Securities and Markets Authority (ESMA) focuses on various aspects of digitalisation in the

ESMA Consultation Paper Guidelines on certain aspects of the MiFID II suitability requirements. BETTER FINANCE highlights that the new concepts introduced by the recent regulatory amendments may be difficult to understand by individual, non-professional investors, creating the risk for them to avoid making a decision or making a wrong decision. In this sense, we suggest

More than a year after the entry into force of the revised Markets in Financial Instruments Directive (MiFID II) and of the Regulation on Key Information Document for Packaged Retail and Insurance-based Investment Products (PRIIPs KID), BETTER FINANCE sought the views and experience of its member associations and their individual members on the effectiveness of

BETTER FINANCE welcomes the initiative of ESMA to clarify certain aspects related to the application of the MiFID II provisions on the appropriateness test and requirements for execution-only services. In addition, BETTER FINANCE commends ESMA on adapting the Guidelines on suitability assessment for the appropriateness test as the two procedures are, to a certain extent,

We welcome the EC’s initiative to alleviate some regulatory requirements enabling EU capital markets’ potential to boost recovery from the COVID-19 induced economic downturn. However, we wish to warn about the long-term detrimental effects that several provisions and amendments will have on “retail” investor protection if done in “haste” and without proper scrutiny and attention

Summary: General comment The review of the MiFID II framework is timely and should be coordinated with the other ongoing actions and policy areas, i.e. PRIIPs and the work done in the Forum on the Future of the Capital Markets Union. In addition, to ensure a level playing field, the European Commission should also adopt

BETTER FINANCE welcomes this timely assessment and evidence gathering on the application of the new MiFID II rules on disclosure for inducements and costs. However, it is very unfortunate that, in a field that is crucial to investor protection and designed to enhance consumer experience and trust in financial services, the majority of questions are

BETTER FINANCE continues to express deep concern about the unwanted “side-effects” of the MiFID 2 regulatory framework on “lit” equity trading in the EU. Below is the summary response to the ESMA Public Consultation on the review of the MiFID 2 and MiFIR transparency regime for equity and equity-like instruments, the double volume cap mechanism

The European Commission is probing the effectiveness of the product governance rules introduced to the industry in 2018 in its latest consultation on the Markets in Financial Instruments Directive (Mifid). […] In a 94-page consultation document, published yesterday (February 26), the commission stated there was some debate over the efficiency of product requirements and asked participants

After the 2023 AGM season and looking ahead to the 2024 season, BETTER FINANCE and its member organisations voice concerns about the erosion of shareholder rights. Inadequate rules for Virtual Annual General Meetings (AGMs) in some Member States highlight the need for broader engagement and representation frameworks for investors to truly benefit from digitalisation. The

In a recent Financial Times article, Guillaume Prache, Senior advisor at BETTER FINANCE, criticizes the use of Article 8 funds in sustainable investing. He argues that increasing the minimum sustainable investment percentage in these funds is ineffective and prone to greenwashing. These funds often oversimplify sustainability as mere ‘green activities’ and predominantly use an exclusion

Transition investing refers to capital needed to improve economic activities, that are not environmentally friendly at present. Such capital supports the development of innovation and infrastructure, enabling current activities to eventually achieve climate neutrality. The European Commission’s release of the transition finance ‘Recommendation’[1] emphasised the importance of such investments for Europe’s pursuit of environmentally conscious

BETTER FINANCE, alongside other NGOs, urges members of the Economic and Monetary Affairs Committee to ensure that the new ESG Regulation improves the reliability, comparability and transparency of ESG Ratings in the EU and in particular to: 1. mandate ESG ratings to follow a double materiality approach, therefore taking into consideration companies’ exposure to ESG

BETTER FINANCE members UK Shareholders’ Association and ShareSoc (UK Individual Shareholders Society) published a letter expressing disappointment in the news that the UK government is abandoning some of its reforms to accounting standards: It is difficult to overstate the disappointment of investors, and other users of corporate information, at the news that the UK government

BETTER FINANCE welcomes the horizontal and vertical dimensions represented in the objectives of the taxonomy. Furthermore, we would like to suggest expanding the horizontal dimension based on the promotion of gender equality which should not be based only on the gender pay gap but also on freedom of expression, assembly, etc.

Retail investors are increasingly concerned about the impact of their investment decisions on society and the environment. In recent years, European Union (EU) institutions have amended the legislation regarding the distribution of retail investment products by investment firms–the Markets in Financial Instruments Directive (MiFID II)–and related delegated legislation and guidelines to define how investment firms

10 February 2023 | As EU policymakers continue their negotiations on the MiFIR review, BETTER FINANCE is increasingly alarmed that the regulation could severely hurt retail investors, by putting in place a market structure further benefitting dark Systematic Internalisers (SIs). Ignoring the previous plea from BETTER FINANCE and going against the interests of retail investors,

The practice of greenwashing, or marketing a product as environmentally friendly, when in fact basic environmental standards have not been met, can take many forms including misleading labels and unsubstantiated/vague claims, meaningless catchwords, etc. with the aim of making a product or company seem greener and more socially responsible than it really is, amounting to

As shown by independent research into the real net returns of European pension savings carried out by BETTER FINANCE, pension savings products too often significantly underperform capital markets, and even sometimes destroy the real (after inflation) value of pension savings over the long-term due mostly to high fees and commissions. This, in turn, is also

Climate change and sustainable development are more and more present in policymaking.  Following the agreement of the Paris Climate Summit ( COP21)  entering into force on the 4th November 2016 and the adoption by the United Nations of the Sustainable Development Goals (SDGs), establishing a framework for global public engagement in environmental and social matters,

BETTER FINANCE, the European Federation of Investors and Financial Services Users, has published a position paper on the European Commission’s Retail Investment Strategy (RIS) proposals. The organisation fully supports the EC’s RIS objectives: consistent rules, enhanced retail investor protection, unbiased advice, competitive financial markets, and transparent and comparable product information. The RIS constitutes a once-in-a-lifetime

Today the appointment of Charles-Henri d’Auvigny as a member of the Board of the Autorité des marchés financiers (AMF) was announced. The Board is the highest governance body of the AMF, whose primary legal mission is the protection of savings. Charles-Henri d’Auvigny is President of the F2IC (Fédération des Investisseurs Individuels et des Clubs d’Investissement)

On 23 March, MEPs Isabel Benjumea and Stéphanie Yon-Courtin addressed the Global Money Week webinar on “Investor Education in times of High Inflation, Financial Repression & Market Volatility” jointly organised by BETTER FINANCE and EFAMA. Please find their respective full speeches below. Excerpts: Isabel Benjumea: “Investor education is a key tool for the completion of

Keynote address by Jella Benner-Heinacher on market structures, “retail” investors, and payments for order flows (PFOF) Thank you for the invitation and congratulations to FESE to organize such an impressive conference in Prague. I would have loved to be personally in this beautiful city of Prague but unfortunately, I can only attend virtually. Nevertheless, I

17 November 2022 – The struggle against conflicts of interests and to deliver an adequate, high level of “retail” investor protection now hinges on the positions of representatives of the EU Member States (Council of the EU). BETTER FINANCE firmly advises the co-legislator not to hamper EU progress and to support the proposal to ban

Individual, non-professional (“retail”) investors are significantly interested in sustainable investments and by extension rely not only on more data on climate or sustainability-related risks and opportunities, but also on more comparable, and comprehensible data in order to understand the risks and opportunities entities are exposed to. In order to ensure investors receive consistent, comparable, and

In 2021, the total income generated by securities lending operations globally stood at €7.8 billion, up by 21% compared to 2020. The majority of operations and lenders are outside the EU, and around 88% of securities on loan were sovereign bonds and equities. In the EU, lenders cannot derive any profit from securities lending. All

Dutch foundation to enable assertion of claims against EY Deutschland and EY Global – at no cost and risk-free. Amsterdam | Düsseldorf | Frankfurt, 06 April 2022 – Wirecard AG’s bankruptcy is likely one of the biggest economic scandals in German history. Within no time it became clear that the high-tech hopes for online payments