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Consultations

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

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

Reply to EC Consultation on corporate governance of financial institutions and remuneration policies

We agree with the European Commission that the weaknesses of corporate governance in financial institutions did contribute to the financial and economic crisis, and welcome the initiative to improve it ...
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/ Consultations

CESR Technical Advice to the European Commission in the Context of the MiFID Review: Non-equity markets transparency

EuroFinuse advocates for the urgent and crucial need to increase pre- and post trade transparency of fixed income products sold extensively to retail investors. In addition, there is a need ...
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/ Consultations, Capital Markets (equity & bonds)

CESR Technical Advice in the Context of the MiFID Review – Equity Markets445670

Small and medium size end investors ask for: - A fact-finding study on the impact of MiFID induced changes on small and individual investors, and the consequences on the economic ...
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/ Consultations, Capital Markets (equity & bonds)

CESR Technical Advice in the Context of the MiFID Review – Investor Protection and Intermediaries

Investor protection is one of the key objectives of the MiFID Directive. EuroFinuse is pleased that CESR has launched a consultation on this critical issue, especially after more than two ...
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/ Consultations