The Commission (DG MARKT) received a total of 80 contributions to its call for evidence on “substitute” retail investment products. The purpose of this feedback statement is to provide a high-level synthesis of these contributions.
Most responses recognised the need to keep the regulatory framework under review to ensure that it delivers an appropriate and consistent level of investor protection.
"Taxation" was the factor driving the promotion and sale of a particular product and the most frequently cited, notably with regard to unit-linked lifeinsurance. "Distribution models" and"cultural preferences" were also deemed tobe significant. "Financial innovation" wasseen as a driver of the success ofstructured securities in some countries.
Consumer associations were concerned about the adequacy of suitability testing in the increasingly important internet distribution channels. Trade unions underlined the need to focus on adequate training of intermediaries and to avoid conflicts in distribution systems linked to commission-based remuneration.
© European Commission
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