EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.
EFAMA is a long-standing advocate of 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 - one of the objectives of the CMU project.
We support harmonised rules governing retail investor participation, as well as a greater emphasis on the benefits of investing, as they would go a long way towards offsetting the phenomenon of European households losing their hard-earned wealth to inflation. We also consider investment advice and its availability essential to increasing retail participation in European capital markets, along with improved financial disclosures and increased financial literacy.
EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.
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.
EFAMA appreciates the opportunity to respond to the IOSCO Retail Market Conduct Task Force's consultation on retail investment trends.
In our view, the IOSCO report provides a comprehensive picture of the retail market trends and risk magnifiers.
We also take the opportunity to share our views on the following areas:
The publication of the European Commission’s long-awaited EU Retail Investment Strategy is an important moment, as creating the necessary conditions to grow retail investor participation in capital markets is key for the future of both the European economy and EU citizens. Within the strategy, we see positive elements which the fund industry has long encouraged, such as digital-by-default disclosures, the preservation of both fee- and commission-based distribution models, and comparable rules for all types of investment products.
EFAMA, together with EBF, Insurance Europe, EACB, EAPB, ESBG and EUSIPA, issued a public letter addressed to Vice-President Dombrovskis, Commissioners McGuinness and Director-General Berrigan, remarking the importance of advice for European retail investors and the need to maintain the coexistence of fee-based and commission-based advice.
EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:
At the Roundtable on the distribution of retail investment products on 18 July 2023, the European Commissioner for Financial Stability, Financial Services and Capital Markets Union, Mairead McGuinness, invited the European Banking Federation (EBF), the European Fund and Asset Management Association (EFAMA) and Insurance Europe to advance an industry-driven process to explore common solutions aimed at increasing retail participation in EU capital markets.
This report analyses the progress made in recent years by European households in allocating more of their financial wealth to capital market instruments (pension plans, life insurance, investment funds, debt securities and listed shares) and less in cash and bank deposits. It also includes policy recommendations on improving retail participation in capital markets, including for the Retail Investment Strategy currently under discussion.
Some key findings include:
The European Commission’s proposal for a Retail Investment Strategy is currently being debated within the European Parliament and Council. As a contribution to this discussion, EFAMA have produced a short leaflet which summarises the needs of EU retail investors, what the proposal gets right, and alternative proposals to consider, with a special focus on disclosures and advice.