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
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
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.