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
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
Please find here an Equiduct LFA analysis on the cost of opportunity of the European equity trades execution based on full depth order book data prices across seven European venues: Xetra, Euronext, Chi-X, Turquoise, BATS, Borsa Italiana and Equiduct HybridBook.
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
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.
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.
We find the Key Investor Information (KII) Template proposed by CESR for investment funds useful, but not clear enough on the “past performance” and “charges” sections. In particular, showing the past performances of a fund alone, without that of any comparable performance indicator is meaningless and could be misleading.
We agree with the European Commission that the weaknesses of corporate governance in financial institutions did contribute to the financial and economic crisis, and welcome the initiative to improve it. Please find our proposals here.
EuroFinuse advocates for the urgent and crucial need to increase pre- and post trade transparency of fixed income products sold extensively to retail investors. In addition, there is a need to ensure a minimum liquidity of these fixed income securities sold to retail investors on the secondary market.
Investor protection is one of the key objectives of the MiFID Directive. EuroFinuse is pleased that CESR has launched a consultation on this critical issue, especially after more than two years of MiFID enforcement and in the light of the current financial crisis. We are however disappointed that CESR did not consult all “stakeholders” on