Feedback (20)

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  • BETTER FINANCE (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/2359 to include the customer’s ESG preferences in the criteria and practical details to be taken into account by insurance intermediaries and insurance undertakings when assessing the suitability of insurance-based investment products for their customers. Investment firms shall act in accordance with the best interest of their clients...

  • 2°Investing Initiative (Germany)
    21 June 2018 Non-governmental organisation (NGO)
    2°Investing Initiative (Germany)

    For our feedback please see the attached file.

  • Finance Watch (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    Finance Watch (Belgium)

    The concept of “best interest” should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility of investors can depend on both financial and non-financial returns. This is particularly critical if we think about the long-term impacts of climate change on future generations and the weaknesses in the current environmental legislations, which do not...

  • WWF European Policy Office (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    WWF European Policy Office (Belgium)

    WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients. It is already a first step that the Commission is moving forward with many of the ‘key actions’ numbered in the EU...

  • Dutch Banking Association (Netherlands)
    21 June 2018 Business association
    Dutch Banking Association (Netherlands)

    The Dutch Banking Association (Nederlandse Vereniging van Banken, or ‘NVB’) welcomes the opportunity to comment on the amendments to MiFID II delegated act, which is part of the Commission proposals on financing sustainable growth (‘Commissions package’). In essence, the NVB endorses the intention behind the Commissions package’s goals. The SDG’s and Paris Agreements present a clear dot on the horizon for banks and the Commissions package...

  • Austrian Federal Economic Chamber, Division Bank and Insurance (Austria)
    21 June 2018 Business association
    Austrian Federal Economic Chamber, Division Bank and Insurance (Austria)

    We welcome the opportunity to comment on the European Commission’s consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products. We would like to point out some practical elements which need to be considered to ensure that the ultimate benefit is afforded to the customer. TIMING The introduction of a transitional period in the draft Regulation is highly appreciated. It provides for a date of...

  • Unipol Gruppo S.p.A. (Italy)
    21 June 2018 Company/business organisation
    Unipol Gruppo S.p.A. (Italy)

    Please see the pdf attached for the Unipol Group's contribution.

  • CDP Europe (Germany)
    21 June 2018 Non-governmental organisation (NGO)
    CDP Europe (Germany)

    Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$87 trillion, we leverage investor and buyer power to motivate companies...

  • Eurosif (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    Eurosif (Belgium)

    Demanding the inclusion of ESG preferences in Distribution of insurance-based investment products, could further contribute to the mainstreaming of sustainable and responsible investment for retail clients. This initiative will certainly increase the level of involvement in sustainability of insurance intermediaries and insurance undertakings, representing an important step in the sustainable finance equation. Being able to link investment...

  • CNMV´s advisory committee (Spain)
    21 June 2018 Company/business organisation
    CNMV´s advisory committee (Spain)

    Please find attached CNMV´s advisory committee comments to the Sustainable Finance Initiative regarding distribution of insurance-based investemnt products.

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