EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.  

We believe that the collection of rules currently governing retail investor participation is either misaligned or tends to focus too narrowly on investor protection and on the risks associated with investing. To offset the phenomena of European consumers losing money by keeping their money in bank accounts, it is critical to focus on the benefits of investing. 

Other recommendations that, in our view, should be included in a successful retail investment plan include:
 

• Easy access to financial advice for retail investors. In this regard, given that that each model of remuneration for advice (fee-based and commission-based) may be the best option for different retail investors, it seems only reasonable that the ideal compensation structure for investors should allow both systems to co-exist.
• Early financial literacy programs for EU citizens, with the European Commission playing a coordinating role across Member States.
• Aligned financial disclosures across various regimes, such as MiFID, IDD and PRIIPs rules. In particular, we are greatly supportive about the resolution of inconsistencies on cost, risk and performance information. 
• A PRIIP KID that focuses on relevant and meaningful information or each type of investment product.

Finally, our members consider it vital for the Commission to invest more time and resources to conducting thorough consumer testing of policy options with retail investors before submitting legislative proposals to the EU co-legislators. This should ensure that the proposed changes create tangible incentives and clear benefits for retail investors, the financial industry and the EU as a whole.