Date: 21st August 2017

Retail” financial services are still ranked as the worst consumer markets in the entire European Union according to the European Commission’s Consumer Scoreboard. Therefore, our organization would like to express its support for initiatives such as the draft Delegated Act since it aims to enhance the protection of consumers and retail investors. We also subscribe to the European Commission’s assessment that insurance-based investment products are often sold as alternatives or substitutes to retail investment products. However, due to many cases of mis-selling of financial products, BETTER FINANCE is concerned that this draft DA diverges to much from EIOPA’s Technical Advice (1st February 2017) and that it seems to set the bar on consumer protection lower than EIOPA’s TA.