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17/10/2017
 

BETTER FINANCE Response to the consultation on the EU Growth Prospectus


On the investor’s side, setting a structure to be followed by the issuer in each section would enhance comparability, transparency and the protection. In order to provide clear and easily readable documents for investors, information displayed should follow the same order in order to harmonize the content and the format of all prospectuses.

Categories: positions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
17/10/2017
 

BETTER FINANCE response to the consultation on the format and content of the prospectus


BETTER FINANCE welcomes the new Prospectus Regulation and the Technical Advice (Level 2) submitted by ESMA. The Technical advice submitted by ESMA reflect the purpose of the Prospectus Regulation: to remove administrative and costs burden for companies and in particular for Small and Medium Enterprises (SMEs) while enhancing investors protection. Investors should be provided with clear, comprehensible and easily accessible information to make their investment decision. BETTER FINANCE however would like to raise two points regarding the Prospectus Regulation and the submitted Technical Advices.

Categories: positions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
17/10/2017
 

BETTER FINANCE Response to the consultation on scrutiny and approval


With regard to the Prospectus Regulation, completeness “relates to undertaking an examination of the prospectus to ensure that it all contains all the information required”. The scrutiny criteria for completeness is relevant for the protection of investors since it will ensure them that all the disclosure items will be included in the prospectus, ensuring that potential investors have access to all information.

Categories: positions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
21/09/2017
 

BETTER FINANCE response to consultation by the European Commission's High-Level Expert Group on Sustainable Finance


BETTER FINANCE answered this consultation by the European Commission's High-Level Expert Group on Sustainable Finance on what the most important issues are that need to be addressed to move towards sustainable finance.

Categories: positions, Corporate Governance
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
12/09/2017
 

BETTER FINANCE response to the EIOPA questionnaire on public disclosure on LTG measures and measures on equity risk


BETTER FINANCE would like to draw attention to a recent study of one of our member organisation, i.e. Bund der Versicherten (BdV), carried out in cooperation with Zielke Research on the current situation of German life insurers (please see the relevant links below). The study is based on the so-called Solvency and Financial Conditions Reports (SFCR), which had to be published by the insurers on EU-level in 2017 for the first time. Unfortunately, the results are poor. Therefore, Better Finance fully shares BdV's serious concerns, especially regarding the low quality and non-sufficient transparency of some of these reports.

Categories: positions, Pensions
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 
21/08/2017
 

Position on the Delegated Act on conduct of business rules for the distribution of insurance-based investment products


Retail” financial services are still ranked as the worst consumer markets in the entire European Union according to the European Commission’s Consumer Scoreboard. Therefore, our organization would like to express its support for initiatives such as the draft Delegated Act since it aims to enhance the protection of consumers and retail investors. We also subscribe to the European Commission’s assessment that insurance-based investment products are often sold as alternatives or substitutes to retail investment products. However, due to many cases of mis-selling of financial products, BETTER FINANCE is concerned that this draft DA diverges to much from EIOPA’s Technical Advice (1st February 2017) and that it seems to set the bar on consumer protection lower than EIOPA’s TA.

Categories: positions, Corporate Governance
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BETTER FINANCE
BETTER FINANCE
 
 
 
 
 

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