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Consultation on the Review of the Insurance Mediation Directive (IMD)

We support the objectives of the consultation launched by the European Commission on the review of the Insurance Mediation Directive. It is essential to increase the level of policy holder protection to obtain the highest possible level, by improving the quality of information provided to customers. Thereby reinforcing transparency through the disclosure of total costs and of the inducements to avoid or at least spotlight conflicts of interest, harmonize the distribution of Insurance PRIPS.

Categories: positions, Insurance
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Review of the Markets in Financial Instruments Directive (MIFID)

Overall, MiFID has contributed to the further marginalization of individual investors, despite the fundamental economic purpose of the capital markets (as opposed to intermediate finance) that is to connect directly end investors and issuers of capital. MiFID facilitates the re-intermediation of equity markets to the benefit of financial intermediaries - especially those who could invest in information technology to profit from the fragmentation - and to the detriment of non financial issuers as well as end investors, pushing those further to “packaged” - i.e. high embedded commissions - products.

Categories: positions, Investment, Financial Markest Infrastructure
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Legislative steps for the Packaged Retail Investment Products initiative

We strongly support the “horizontal” approach taken by the European Commission for its Packaged Retail Investment Products (PRIPs) initiative, which is the right way to harmonize selling practices of retail investment products because most of them are “substitutable” for each other, and most of them are or can be sold by the same intermediaries. Please read more here.

Categories: positions, Investment
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Guillaume Prache

Legal Certainty of Securities Holdings and Disposition

The legal information flows regarding securities holdings and disposition should be simplified, made fully available to real (economic) shareholders and issuers via the Internet, to no extra cost for retail investors, especially for cross-border holdings and for the exercise of cross-border voting rights, either directly or via proxies. The necessary holding and disposition information services from the real (economic) shareholder to the issuer should be split from the custody services currently performed by financial intermediaries.

Categories: positions, Securities Law
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Green paper towards adequate, sustainable and safe European pension systems

We fully agree with the Commission that an “adequate” and sustainable retirement income for EU citizens is a priority for the European Union, but proves a major challenge to achieve. The adequacy of unfunded pensions and of those with defined benefits could be defined as the conformity of the results to promises made to participants. Please read more here.

Categories: positions, Pensions
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CESR’s level 3 guidelines on the selection and presentation of performance scenarios in the Key Investor Information document (KII) for structured UCITS

EuroFinuse fears that the proposed guidelines for the choice and presentation of performance scenarios will mislead information for retail investors. These performance scenarios should reflect probable or highly probable returns in order to guide investors and be consistent with the EC Regulation implementing the Investment Funds Directive.

Categories: positions
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