A group of financial sector associations — including Insurance Europe — have written
 jointly to the European Commission to highlight the fact that the 
impact of an EU-wide ban on commission would vary greatly across member 
states; could negatively impact consumers in countries with a 
commission-based model; and severely undermine the goals of the EU’s 
Retail Investment Strategy (RIS). 
If properly calibrated, the RIS
 presents a significant opportunity to promote an open and competitive 
financial market where consumers can invest with confidence and have 
access to a diverse range of investment opportunities.
To achieve 
the goals of the RIS, it is important to recognise the value offered by 
professional advice to consumers. Such advice enables consumers to take 
effective investment decisions, plan for their future and meet their 
sustainability preferences. Therefore, an EU-wide ban on commission, 
which would limit consumers’ access to advice, would disrupt the market 
at the expense of consumers. 
While any professional service and 
advice come at a price, the cost of not being able to access advice when
 needed would be extremely high for consumers. Some risk turning to 
other sources of information like social media and being more exposed to
 scams or high-risk investments, while others would be less likely to 
invest, and then less prepared for retirement. Furthermore, an EU-wide 
ban would not respect market diversity in terms of distribution systems,
 clients’ preferences and supervisory culture.
Moreover, the 
Insurance Distribution Directive (IDD) introduced strong safeguards 
against conflicts of interest and mis-selling, and member states have 
added specific national provisions where appropriate. The approach taken
 in the IDD must, therefore, be preserved. 
The
 RIS should focus on what is really useful and necessary for a simple 
and smooth consumer experience; make disclosures more consumer-friendly 
and fit for the digital age; and promote much needed financial and 
insurance education.
The other signatories are: The European Fund 
and Asset Management Association, the European Association of 
Cooperative Banks, the European Structured Investment Products 
Association, the European Banking Federation, the European Association 
of Public Banks, and the European Savings and Retail Banking Group. 
InsuranceEurope
      
      
      
      
        © InsuranceEurope
     
      
      
      
      
      
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