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EBF made public its response to the Commission call for evidence on product transparency and distribution requirements for “substitute” retail investment products.
EBF stated that the existence of different investment products and a competitive asset management landscape should be seen as desirable. Therefore, the main question to be considered should be that of due investor protection, EFB underlined.
“The MiFID provides a benchmark in this regard, especially through its suitability and appropriateness tests and its information requirements”, EBF notes, calling them as effective and sufficient. “There is clearly no need for any additional regulation for products to which the MiFID applies.”
EBF notes that “if the Commission intended to give more consideration to investor protection standards for products not covered by the MiFID, this could only be done in a meaningful way at a point in time when the MiFID has been fully implemented within the industry”.