BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive.
Investment firms shall act in accordance with the best interest of their clients. As such, when providing investment advice and portfolio management, they must disclose information on the ESG of each financial product offered to the client before providing investment services.
The asset managers must explain to the client how his or her ESG preferences for each financial instrument is taken into consideration during the advice process.
BETTER FINANCE fully supports this proposal to include ESG considerations during the advisory and product suitability process. However, we have some concerns regarding the proposal.