ALFI appreciates the opportunity given by the Commission to contribute to the reflexions on third-pillar products and in particular on consumer protection aspects in this context. ALFI agrees that consumer protection is of highest importance for such products, where a product shall be offered to consumers which will have a long to very long time horizon and which will have limited to no liquidity.
ALFI firmly believes that it is essential to ensure that consumers are aware of the characteristics of such product and subscribe to it on a fully informed basis, so as to avoid any misunderstandings and bad surprises which could affect the credibility of such product.
It appears to us that in order to create a suitable background for the success of a third-pillar product, consumers should ideally understand the economic situation where first pillar retirement guarantees may be or become insufficient to cover the needs of retired persons, which should create an incentive for consumers to subscribe to individual retirement products.
As results from our answers on the specific questions below, ALFI would like to underline its conviction that better informing and educating the investor will be absolutely key to achieve successful third-pillar retirement products.
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© ALFI - Association of the Luxembourg Fund Industry
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