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Publications

Technical details of a possible European crisis management framework

This consultation from the European Commission is part of the European Authorities efforts to prevent any future financial crisis of the magnitude of the 2008 one. Most questions are not ...
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/ Consultations

Consultation on the Review of the Insurance Mediation Directive (IMD)

We support the objectives of the consultation launched by the European Commission on the review of the Insurance Mediation Directive. It is essential to increase the level of policy holder ...
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/ Consultations

MiFID Review – The European equity markets fragmentation has penalized small investors

The European MiFID Directive in force since November 2007 has pushed the European equity markets to fragment into multiple “trading platforms”: besides the existing “regulated markets” (RMs) “multiple trading Facilities” ...
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/ Press Releases, Capital Markets (equity & bonds)

Review of the Markets in Financial Instruments Directive (MIFID)

Overall, MiFID has contributed to the further marginalization of individual investors, despite the fundamental economic purpose of the capital markets (as opposed to intermediate finance) that is to connect directly ...
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/ Consultations, Capital Markets (equity & bonds)

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

European equity trades execution – Cost of opportunity analysis

Please find here an Equiduct LFA analysis on the cost of opportunity of the European equity trades execution based on full depth order book data prices across seven European venues: ...
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/ Research papers

Legal Certainty of Securities Holdings and Disposition

The legal information flows regarding securities holdings and disposition should be simplified, made fully available to real (economic) shareholders and issuers via the Internet, to no extra cost for retail ...
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/ Consultations, Other, Securities Markets & Trading

Green paper towards adequate, sustainable and safe European pension systems

We fully agree with the Commission that an “adequate” and sustainable retirement income for EU citizens is a priority for the European Union, but proves a major challenge to achieve ...
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/ Consultations, Life Insurance & Pensions, Sustainabe Finance

CESR’s level 3 guidelines on the selection and presentation of performance scenarios in the Key Investor Information document (KII) for structured UCITS

EuroFinuse fears that the proposed guidelines for the choice and presentation of performance scenarios will mislead information for retail investors. These performance scenarios should reflect probable or highly probable returns ...
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/ Consultations

The Key Investor Information Template

We find the Key Investor Information (KII) Template proposed by CESR for investment funds useful, but not clear enough on the “past performance” and “charges” sections. In particular, showing the ...
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/ Consultations