EuroFinUse: Response to the Consultation by DG SANCO on Consumer protection in third-pillar retirement products

19 July 2013

EuroFinUse is pleased that the EC is aware of some of the severe problems currently existing in the area of private pensions, such as regulatory fragmentation, lack of transparent and clear information for consumers, and difficulties for consumers to choose between different substitutive products.

However, EuroFinUse believes that the Commission may not be aware of the extent to which these problems cause consumer detriment in the area of private pensions:

• For instance, with regard to regulatory fragmentation issues, EuroFinUse would like the European Commission to note that the very restricted scope of the Regulation for Key Investment Documents (PRIPs)  is certainly not contributing to create the very much needed level playing field for retail long term investment products. The Internal Market and Consumer Protection Committee (IMCO) of the European Parliament shared EuroFinUse’s opinion on the inclusion of occupational pension products within the scope of the Regulation, in the same way as the ECON Rapporteur did for the inclusion of shares and bonds. This is why EuroFinUse believes the proposed exclusion from the scope of the Regulation of all kinds of pension products and of several categories of life insurance by the European Council last draft does not go in the right direction to strengthen the confidence of consumers in the EU market for private pension products.

• Also, EuroFinUse's recent independent research shows that too many private pension products (“3rd pillar”) destroyed the real value of EU citizens’ pensions savings and are unfortunately quite likely to continue doing so in the years to come, unless strong and long-awaited action from the EU Authorities in the area of long term and pension savings takes place.

Full response

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