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Organisational requirements
EBF is not convinced that amending general organisational requirements for investment firms is the most appropriate way to integrate sustainability risks in their advisory process. If included, it is important to clearly identify the specific organisational requirements and provide further guidance on how they should be applied by firms.
EBF supports the high-level principle-based approach for the integration of sustainability risks within the MiFID II requirements, similar to that one already followed for all other relevant risks.
EBF would also like to remark the need of coordination with the EU proposed regulations on Sustainable Finance in order for terms and expressions to be given the same meaning.
EBF would like to see further clarifications on specific aspects of conflicts of interest.
Product Governance
Regarding market standards and “labels”, EBF advocates for a positive yet gradual approach while warning against their, sometimes, national character, and concerns with possible greenwashing.
EBF urges supervisors and legislators to embrace, as much as possible, pro-active market initiatives already set up. And to not interfere with them until the EU harmonised framework and regulation is in place.
Clients that have expressed ESG considerations may be offered “non-ESG” products if appropriately informed about this in the suitability report.
Suitability
It is essential to provide as much flexibility as possible for the methods used by firms for integrating ESG preferences within their suitability model.
Two-step approach towards clients’ preferences: Only asking detailed ESG questions when clients indicate a positive interest in ESG considerations.