Omnibus directive:

ALFI welcomes as such the goals of the RIP, notably that retail investors should receive adequate value for money, the aim of improving transparency and of facilitating access to professional investor status, as well as the promotion of financial education.

Nonetheless, ALFI is very much concerned about some aspects of the proposed omnibus Directive, in particular the benchmarking approach for the value for money concept and the changes to the inducements provisions, which may overall eventually add hurdles rather than easing investors’ access to capital markets and run counter the objective of the Capital Markets Union.

PRIIPs Regulation:

ALFI thinks that summarising key information in a dashboard at the beginning of the document would be helpful at least for those investors which do not want to dive into technical details.

Article 8(5) and 10(2) provide for a submission of RTS by only one year after the date of entry into force of the amending regulation. However, after submission, several months will go by until final RTS will be adopted and published, which means that the availability of technical guidance and the application date of the new rules (18 months after the entry into force of the amending regulation) would more or less coincide. Managers will not invest a significant amount of money, e.g. to develop new tools, before specific guidance is set in stone. To avoid legislative processes similar to the past PRIIPs quick fixes, the amending regulation should only apply 12 months after the publication of level 2 rules in the Official Journal.

View the ALFI response.