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30/01/2018
 

BETTER FINANCE feedback on the review by the ESAs of Solvency II


BF agrees that divergence in the supervision and approval of internal models for Solvency Capital Requirement (SCR) leads to inconsistencies and can create both an uneven level playing field for market participants, and an inconsistent protection of EU citizens as insured persons. Actually, BETTER FINANCE believes that the use of “internal models” is an advantage given to the larger insurance institutions over smaller ones, and even more importantly is a barrier to a fair, clear and not misleading information to the customers, as it is almost impossible for them to evaluate those “internal models”.

Categories: positions, Insurance
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
30/01/2018
 

BETTER FINANCE feedback on the EBA Relocation Proposal


BETTER FINANCE welcomes this opportunity to comment on the relocation of the European Banking Authority (EBA). Following the United Kingdom’s decision to leave the European Union by 30th March 2019, the General Affairs Council selected Paris as the new seat for the EBA. Currently, the EBA is almost entirely focused on regulatory issues, not on supervisory ones. Of further concern to EU citizens as users of banking services, the EBA has not been very active active in terms of retail user protection.

Categories: positions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
20/12/2017
 

Request to the European Supervisory Authorities to report on the cost and past performance of the main categories of retail investment, insurance and pension products


Guillaume Prache, Managing director of BETTER FINANCE, was asked by EIOPA to contribute to the discussion on the request for the European Supervisory Authorities to report on the cost and past performance of the main categories of retail investment, insurance and pension products. He was the rapporteur of the recently adopted OPSG (EIOPA Occupational Pensions Stakeholder Group) position paper on this topic.

Categories: positions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
12/12/2017
 

Impact Assessment - Institutional Investors and asset managers duties regarding sustainability


In order to effectively contribute to the strengthening of the Capital Markets Union, BETTER FINANCE believes that sustainable investment products require binding standards ensuring the trust of EU citizens in sustainable retail investment products and positive returns.

Categories: positions, Corporate Governance
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
01/12/2017
 

BETTER FINANCE on crowdfunding and peer to peer lending


BETTER FINANCE welcomes the initiative from the European Commission to consult stakeholders on a legislative proposal for an EU framework on crowd and peer to peer finance. BETTER FINANCE already raised the issue that only a limited number of the larger SMEs are likely to benefit from Capital Markets Union. As part of the 2015 CMU action plan, this initiative would broaden the access to finance for SMEs. Crowdfunding and peer to peer lending would thus represent an alternative source of financing for small SMEs.

Categories: positions, Consumer Affairs
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
01/12/2017
 

Feedback on the revision of the Injunctions Directive


BETTER FINANCE (BF) welcomes the opportunity to comment on the Inception Impact Assessment on the revision of the Injunctions Directive. The right to claim compensation and the right to access to justice should not remain theoretical for consumers and investors. It is especially important in the area of financial services where quite technical and complex financial products have a serious impact on the quality of life of active and retired citizens and where due to the lack of an effective redress mechanism many consumers are unable to exercise their rights.

Categories: positions, Securities Law
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 

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