Make RIS only applicable to new investment-related products 

A number of new rules, which Brussels wants to include in the Retail Investment Strategy (RIS) after political negotiations, are duplicative and unnecessary for the Dutch insurance market. This is stated by the Association ina response to the Commission's plans for the Retail Investment Strategy.  

In the RIS proposals, the European Commission has not taken into account member states that already have a complete ban on commissions for complex investment-related products. "Like the Netherlands," says Richard Weurding, general director of the Association. "The proposed benchmarking (on cost and performance) and the associated pricing process based on the Value for Money concept (VfM) will lead to an enormous administrative burden for providers of these products. That is why the Association argues for an exemption from the VfM concept.

RIS only for new investment-related products

The Association also calls for the RIS proposals to be applied only to new investment-related products. "In most cases, it is not possible to find out all the costs of existing insurance policies charged by the insurer and fund managers, it is very labour-intensive (a lot of manual work) and therefore expensive." In addition, Weurding expects that the introduction of the new RIS terminology and calculation methods for performance scenarios will cause a lot of confusion among current clients of investment products," says Weurding. 

Light regime for non-complex financial products

The Association sees the European Commission's initiative to adjust the appropriateness and suitability tests as a positive development to lower barriers for retail investors. It offers opportunities for innovation and for the development and introduction of new business models. 

Deployment of the Commission at RIS 

The European Commission wants to use the RIS regulation to encourage retail investors to become more active in the European investment markets. The confidence of retail investors in the European financial markets must be increased through a partial ban on commissions (for independent advice and execution-only services) on investment-related products. And by including the VfM concept in the RIS, the Commission aims to reduce the cost of European investment-related products in order to increase the value of these products. This is done through a solid framework with benchmarks and a pricing process.