Bank customers ask for a guide to understand and apply the Green MiFID


In order to improve the contracting of retail customers in Spain, the consumer association Asufin and the NGO WWF have been transferred to the National Securities Market Commission (CNMV) the preparation of a technical guide and a detailed model questionnaire to offer granular guidance to financial advisors in Spain, with the aim of improve compliance and integration of sustainability preferences. Both organizations state that the guidelines given by the European Securities and Markets Authority (ESMA) on the reform of the directive MiFID II regarding the suitability test on sustainability are “too general to understand how to correctly distinguish investor preferences”.

Among the recommendations, they point out that the CNMV should promote the development of independent comparators that facilitate the investment decisions of retailers and make it possible to easily compare the cost, the characteristics of the investment products and their degree of sustainability. In turn, both organizations request that the supervisor periodically carry out a series of ‘mystery shopping’ exercises in order to assess how financial advisors apply the new requirements and assess ESG product types.

In addition, they consider it convenient for investment companies to propose some type of retail customer explanatory brochure and use visual and simple material while carrying out the explanation of what the sustainability preference is. Lastly, the letter sent states that the CNMV should modify information collection on the sustainability preferences of retail customers is a simple box-ticking exercise.

“Integrating retail customer sustainability preferences is a critical step for the implementation of the EU sustainable finance agenda and the transition to a more sustainable economy. Therefore, this exercise is key to gradually reallocate capital. This change in behavior can only be achieved with an adequate assessment of suitability and the correct collection and attention to customer sustainability preferences”, explained the head of the climate and energy program at WWF, Sea Asuncion.

“It is possible that the retail client does not have the necessary knowledge to distinguish between sustainable products, nor between these regulations because they are too technical. The advisors are the ones who must explain it properlyincluding the different degrees of expectations related to sustainability or the minimum proportion that would be relevant”, pointed out the president of Asufin, patricia suarez.


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