ALFI preliminary statement on the European Commission Retail investment package

09 June 2023

ALFI fully supports the European Commission’s ambition to create the necessary conditions to enhance retail investor participation in capital markets in line with the core objective of the Capital Markets Union to ensure that consumers can fully benefit from investment opportunities.

The proposed legislative measures in the Omnibus Directive, which concerns five different directives and the proposal to amend PRIIPs Regulation contain a broad range of significant changes for the financial industry.
ALFI fully supports the European Commission’s ambition to create the necessary conditions to enhance retail investor participation in capital markets in line with the core objective of the Capital Markets Union to ensure that consumers can fully benefit from investment opportunities. To support this ambition, ALFI advocated in the context of the preceding consultation especially for more transparency on third-party costs, easier access to the professional investor status for knowledgeable retail investors and fostering financial literacy. In this sense, ALFI welcomes as such the goals of the RIS, 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, there are a number of concerns that have been addressed to date. In particular, questions arise around the potential practical implementation of the benchmark approach in the value for money assessment and on the yet uncertain implications that may come along with the proposed mandate to ESMA and EIOPA to detail such requirements.
In general, ALFI notices that large parts of the proposal are foreseen to be detailed in the future through level 2 and 3 measures, the impacts of which may be far reaching. The proposed ban on inducements in an execution-only context may also have far reaching consequences for both the retail investor and the financial industry, and should therefore be thoroughly assessed.
ALFI is currently analysing and discussing the RIS package with its members with a view to providing comments to the European Commission.

ALFI

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