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Consultations

Towards a coherent approach to Collective Redress

We welcome the opportunity to comment on Collective Redress. We regret though that the European Commission despite its long term awareness of the existing problems facing investors and all other ...
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/ Consultations

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

DAF Technical details of a possible EU Framework for Bank Recovery and Resolution

Technical details of a possible EU Framework for Bank Recovery and Resolution Danish Shareholders Association is the organisation representing private investors in Denmark, and finds the proposal on bank recovery ...
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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

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