Key points include:
- We support the green paper’s objectives of harmonising consumer protection and lowering prices for consumers. However, the scope of the initiative should be expanded to include more consumer protection measures, rather than focusing on cross-border issues that concern relatively few citizens.
- The initiative aims to increase digitalisation and cross-border selling of retail financial services, which should benefit prices and comparability and reduce administrative burdens. However, the Commission should anticipate the potential downsides from promoting these trends, which could include digital exclusion, less consumer redress, increased miss-selling, net job destruction, tax avoidance, and more unstable lending across borders, among other things.
- Improvements to competition should be based on a regulatory level playing field that does not favour dominant players. Otherwise, an increase in market concentration could occur and lead to reduced diversity and resilience of our financial system.
- EU-level action should promote and incentivise a range of basic products for retail investors. Simple, comparable products should be universally available and easy to identify. They could be promoted by extending to all retail financial products the comprehension alerts developed in PRIIPs and key investor information document used for UCITS.
