ALFI submits a position paper on the European Commission proposal on a retail investment package (RIP)

The ALFI has expressed its position on the European Commission’s proposal for a retail investment package, which includes the Omnibus Directive and the PRIIPs Regulation. ALFI believes that the proposal has some positive elements, but also raises concerns about certain provisions that could negatively impact investors and stifle innovation.
One of the main concerns is the use of benchmark assessments to evaluate the value for money of investment products. ALFI argues that this approach would narrow competition and limit the range of investment options available to investors. Instead, they suggest disclosing in clear language how each product provides value for the money invested. Additionally, ALFI opposes the proposed ban on inducements in an execution-only context without advice, as it could disrupt the distribution of investment products.
Regarding the PRIIPs Regulation, ALFI suggests summarizing key information in a dashboard at the beginning of the document to help investors quickly understand the product’s features. They also recommend disclosing sustainability information as an integral part of the fund’s investment process. However, ALFI notes that building interactive tools for comparing costs across different financial market participants would be technically complex and costly.
Finally, ALFI expresses concern about the timing of the submission and adoption of RTS, which could result in a gap between the entry into force of the amending regulation and the availability of technical guidance. They recommend that the application date of the new rules should only coincide with the publication of level 2 rules in the Official Journal to avoid legislative processes similar to the past PRIIPs quick fixes.