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General remarks:
EACB welcomes IOSCO’s consultative report aiming towards more efficient selling practices in order to enhance investor protection for retail clients, as it agrees with the envisaged introduction of a level playing field concerning the rules for the sale and disclosure requirements for retail structured products.
European cooperative banks are characterised by a decentralised network of branches with a very strong retail base serving approximately 181 million retail clients in the European Union. Cooperative banks are therefore amongst the major distributors of a large variety of retail investment products.
While EACB appreciates IOSCO’s reflections and proposed ideas, it would like to draw attention to the European Union’s wide-reaching activities in the areas covered under this consultation. From a European perspective, some proposed provisions are already covered under the Market in Financial Instruments Directive (MiFID) and UCITS IV legislation (which requires Key Investor Document for European investment funds) while others are currently discussed in the MiFID revision and the Key Investor Document (KID) initiative which aims to provide a KID for all structured products sold to retail investors.