In July the European Commission released their long-awaited Retail Investment Strategy, including multiple proposals aimed at boosting retail participation in capital markets. EFAMA has provided comments on this in their ‘Have your say’ forum, where we briefly highlight some of our main concerns.
Retail Investment
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.
EC "HAVE YOUR SAY" consultation on the EU Strategy for Retail Investors
Joint Industry letter on the importance of advice and preserving the commission-based model
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.
ESMA’s Consultation paper on the review of the guidelines on MiFID II product governance requirements
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:
Joint Industry Statement on the EU Retail Investment Strategy
On 24 May 2023, the European Commission unveiled the most extensive reform of the EU legislative framework for retail investment to-date. As representatives of the European financial and insurance sector, we (AMICE, EACB, EAPB, EBF, EFAMA, ESBG, EUSIPA, Insurance Europe) are still assessing the full range of impacts and changes put forward in the Retail Investment Strategy (RIS) across multiple pieces of regulation: MiFID II, the Insurance Distribution Directive, the UCITS Directive, the Alternative Investment Fund Managers Directive, the PRIIPs Regulation and the Solvency II Directive.
European Commission’s Retail Investment Strategy includes positive elements, however the impact of some initiatives remains unclear
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.
Joint Industry letter on the importance of advice and preserving the commission-based model
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.
Retail Investment Strategy: what to keep, what to remove and how to simplify moving forward
In its current form, the Retail Investment Strategy (RIS) will not achieve its goal of making investing more accessible to European citizens and could deter, rather than encourage, retail participation. In order to stand a chance of delivering on its objectives, the RIS needs urgent simplification. EFAMA have produced a short leaflet with our recommendations on how to simplify and reduce complexity in the current proposal.
Our key suggestions include:
Charting the Course: Unlocking Retail Participation in EU Capital Markets
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.
Household Participation in 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: