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Changes to the Capital Requirement Directive

We do not believe a regulatory initiative such as the changes to the Capital Requirements Directive really addresses the major issue revealed by the financial crisis. The roots of the 2008 financial crisis are indeed clearly identified by now. Irresponsible mortgage lending to US households has been an initial trigger of the worst financial crisis since 1929. In turn, this irresponsible lending came largely from the quite recent development of the packaging of these loans through securitization, which – together with questionable accounting practices – enabled banks to take these loans off balance sheet. If these mortgage loans had stayed 100% on the banks’ books, it is unlikely any “sub prime” crisis would have occurred, at least with this magnitude.

Categories: positions, Banking
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“Packaged” Retail Investment Products (PRIPs)

We strongly support the new “horizontal” approach of the EC, which is the right way to look at the distribution of retail investment products, as most of them are “substitute” to each other, and most of them are or can be sold by the same intermediaries. We nevertheless regret that the retail investor’s perspective is not enough taken into account. Please read our full position paper here.

Categories: positions, Investment, Pensions
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Guillaume Prache

CESR’s technical advice at level 2 on the format and content of Key Information Document disclosures for UCITS

We have worked extensively on the KID project over the last two years, and feel that CESR is now getting close to fulfilling the mandate given by the European Commission to design the new “KID” that will likely constitute a significant improvement for fund investors’ information and protection.

Categories: positions, Investment
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Guillaume Prache


The latest edition of our report on Pension Savings is now available for download!