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Publications

BETTER FINANCE’s answers to DG FISMA’s Discussion Note on Value for Money

Would you agree with the assessment that certain products that are offered to consumers do not offer Value for Money? If yes: a) how significant a problem would you consider this ...
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/ Consultations, Life Insurance & Pensions, Packaged Investment Products, Product governance & disclosures, Supervision & Redress

BETTER FINANCE response to ESMA Public Consultation on the Review of the Guidelines on MiFID II product governance requirements

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/ Consultations, Capital Markets (equity & bonds), Packaged Investment Products, Product governance & disclosures

BETTER FINANCE answer to European Commission Consultation on resolving consumer disputes out-of-court

EXECUTIVE SUMMARY What is Alternative/Online Dispute Resolution (ADR/ODR)? Non-judicial procedures through which consumers (for our constituency, “retail” financial services users) can solve disputes with professionals and obtain redress for their ...
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/ Consultations, Other, Product governance & disclosures, Supervision & Redress

BETTER FINANCE response to the Consultation Paper Guidelines on certain aspects of the MiFID II suitability requirements

ESMA Consultation Paper Guidelines on certain aspects of the MiFID II suitability requirements.
  1. BETTER FINANCE highlights that the new concepts introduced by the recent regulatory amendments may be difficult ...
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/ Consultations, Capital Markets (equity & bonds), Packaged Investment Products, Product governance & disclosures

BETTER FINANCE answer to EIOPA Consultation Paper regarding draft Advice on certain aspects relating to retail investor

INTRODUCTORY EXPLANATIONS (for non-professional readers) European Union (EU) authorities aim to improve the conditions of saving and investing in capital markets for EU households through several regulatory and supervisory actions ...
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/ Consultations, Life Insurance & Pensions, Packaged Investment Products, Product governance & disclosures

BETTER FINANCE reply to EIOPA’s Public Consultation on a ‘Framework to address value for money risk in the European unit-linked market’

BETTER FINANCE welcomes this unique initiative from EIOPA as an example of best practice in terms of supervision and investor protection, not only at the EU level but on the ...
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/ Consultations, Life Insurance & Pensions, Packaged Investment Products, Product governance & disclosures, Supervision & Redress

A new European regime for Venture Capital

Please read here EuroInvestors response to the European Commission public consultation on " ...
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/ Consultations, Financial Reporting & Audit, Product governance & disclosures, Securities Markets & Trading, Supervision & Redress

Legislative steps for the Packaged Retail Investment Products initiative

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 ...
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/ Consultations, Life Insurance & Pensions, Packaged Investment Products, Product governance & disclosures

“Packaged” Retail Investment Products (PRIPs)

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” ...
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/ Position Papers, Packaged Investment Products, Product governance & disclosures

CESR’s technical advice at level 2 on the format and content of Key Information Document disclosures for UCITS

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 ...
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/ Consultations, Packaged Investment Products, Product governance & disclosures