Date: 5th January 2022

BETTER FINANCE welcomes this call for evidence from ESMA on retail investor protection topics but regrets that it is confined to securities markets (MiFID II) topics only as these financial instruments make up for only a third of the financial balance sheets of EU27 households and in fact the smallest share of the three largest financial product categories: insurance product and pensions (34%), banking products (32%) and MiFID II product (31%) in 2020. Therefore, BETTER FINANCE’s general recommendation is to avoid the silo approach by the European Commission and adopt a more coordinated/harmonised view of retail investor protection topics.