ALFI responded to the European Commission’s call for evidence on the need for a coherent approach to product transparency and distribution requirements for “substitute” retail investment products. The Association’s standpoint is to provide the Commission with an overview of product types which do not fall under the investment funds banner but may be considered as a source of unfair competition in relation to UCITS. Practical examples of missellings to investors in this context are also given, and the question of the advantages and disadvantages of UCITS and nationally regulated funds versus substitute retail investment products is also addressed in this paper. Finally ALFI makes recommendations as to the product disclosure in relation with MiFID rules and the Prospectus Directive’s provisions.
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