The European Association of Co-operative Banks (EACB) welcomes the opportunity to participate to the ESMA Consultation Paper on Draft guidelines on MiFID II product governance requirements.
The concept of target market and enhanced product governance requirements are important new features in MiFID II when it comes to investor protection. The EACB has closely followed the debate on potential level III measures and considers that it is important to provide clear and harmonised EU-level guidance in target market in order to facilitate smooth provision of investment services cross-border.
Having reviews the proposed guidelines carefully with its members, the EACB has worked on responding to the various consultation questions, plus some overarching concerns.
