Europe’s co-operative banks serve 214 million customers (around half the population of the EU), who are mainly consumers, retailers, SMEs and communities. This makes them drivers of local and social growth, and major contributors to financial and economic stability by merit of their anti-cyclical behaviour. The main service provided to the retail markets by co-operative banks is the provision of credit – the biggest market share being in consumer loans and mortgage loans – but they also act as manufacturers and distributors of retail investment products. In addition, co-operative banks provide investment services and investment advice to retail clients, most notably as defined under MiFID II and PRIIPs. Therefore, retail investor protection is an important topic for the EACB to address by way of the rules behind the provision of investment advice, the assessment of client suitability, adequate transparency of ex-ante and ex-post investment information to clients (e.g. PRIIPs KID and MiFID cost disclosures), and the topic of bias-free advice which we understand are all concerns of the Retail Investment Strategy under the new CMU action plan of September 2020.
Our detailed answers to the call for evidence can be found in our position paper.