Position paper - Retail Investment Strategy

The recent European Commission proposal on the Retail Investment Strategy (RIS) appropriately aims to empower retail investors and facilitate their ability to take full advantage of capital markets. We commend the European Commission for introducing measures that aim to:

• Enhance financial literacy.
• Increase digitalisation.
• Ease restrictions to qualify as professional investors.
• Improve suitability and appropriateness assessments.
• Define standards for advisors.

However, despite the good intentions behind certain proposals, some may have negative unintended consequences and should be examined in greater detail as part of the co-legislative process – in particular:

• The introduction of costs and performance benchmarks.
• The concept of the ‘Best Interest Test’.
• The revised advice process, including the execution-only inducements ban.