Advice on the Fundamental Review of the Financial Conglomerates Directive
We would like to answer specifically to the following questions raised by ESMA: What should be the parameter of supervision, where a financial conglomerate is supervised on a group wide ...
Assessing the Suitability of Members of the Management Body and Key Function Holders of a Credit Institution
We believe that the appropriate selection of the members of management boards as one of the key principles of corporate governance. This issue has profound implications for shareholders, consumers, and ...
Overview of the Proxy Advisory Industry Considerations on Possible Policy Options
Proxy advisers serve mostly institutional investors on a commercial basis but their activities have not yet been regulated at EU level. Thus, the ESMA is considering the possibility to regulate ...
Green Paper on Shadow Banking
The European Federation of Financial Services Users (EuroFinuse) supports the Financial Services User Group (FSUG) response to the consultation to this consultation, and part of our response is derived from ...
Liikanen Group Consultation on the Banking Union
EuroFinuse firmly believes that the commercial banking activities (i.e. the intermediated funding of the real economy - businesses and households - should be separated as much as possible from all ...
Gender imbalance in corporate boards in the EU
Self-regulation is not sufficient in our view: the EU has brought about the policy debate on gender diversity in 2010, and called on listed companies in 2011 to voluntary commit ...
Draft proposal for Report on Good Practices for Disclosure and Selling of Variable Annuities
We consider that Variable Annuities (VA) products should be classified as PRIPs as should be all other more “traditional” classical and with profit life insurance products. There should be no ...
Advice on the review of IORP Directive
We fully support the position of the GCAE, emphasizing the necessity of correct, understandable and non misleading information about pensions. “Communication with the members should also explain in simple and ...
Advice on ESMA’s public consultation on UCITS Exchange-tradedfunds in the European Union
We generally agree with the concerns raised by ESMA relating to the increased complexity of ETFs, that raise significant issues both with respect to investor protection and systemic risk. ETFs ...
ESMA call for evidence on Empty Voting
Voting rights and the right to exercise are of vital concern to all European individual shareholders, as it hinders shareholder engagement and good corporate governance. Some of our member organizations ...


