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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

BETTER FINANCE thanks the European Securities and Markets Authority (ESMA) for its “peer review” report on the Wirecard scandal. It is quite revealing of the many failures and conflicts of interests that can plague even the most resourced national financial supervisors. It is unfortunate however that ESMA did not look into the handling by the

In 2016 the Investment Association (IA), a UK-based organisation representing investment managers, published a report that dismisses claims that there are or were hidden fees charged to investors in financial products, in particular related to mutual funds. Renamed ‘The Loch Ness monster of investments’, the study indicates that all charges applied to investors are clearly

BETTER FINANCE continued its research series into Robo-advice with this seventh annual edition (2022), mapping a sample of platforms that provide online Robo-advisory investing services, by analysing their (automated) advice process in terms of transparency, costs, portfolio composition, suitability and sustainability options and preferences for the client. This edition’s analysis focuses on Robo-advisors’ ability to

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

Lately, many shareholders in public limited companies have turned to the PanSlovenian Shareholders’ Association (VZMD) and stated that they have received various letters and very strange offers from IGOR ŠTEMBERGER, the CEO and owner of ILIRIKA bornz-posredniška družba, d.d. (a brokerage company). In certain cases, the offered prices for shares were extremely low. In others, they offered shareholders shares of the company ILIRIKA MOJA

BETTER FINANCE continued its research series into Robo advice with this sixth annual edition, mapping start-up platforms that provide Robo-advisory and investing services, and analysing their user-friendliness, transparency, costs, portfolio composition, the suitability of their recommendations, and sustainability (through mystery shopping). This year the research team selected 18 platforms providing investment advice in 11 countries

BETTER FINANCE replied to the European Insurance and Occupational Pension Authority’s (EIOPA) public consultation on open insurance, focused on access to and sharing of insurance-related data. In its Discussion Paper, EIOPA explores questions on whether and how far insurance value chains should be ‘opened’ up by the sharing of insurance-related and specific policyholder data amongst

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