EBF adviser: Pauline Guérin
Publication date: 28 April 2021
General Comments:
The EBF welcomes ESMA’s effort to give guidelines on how to best apply the appropriateness test requirements.
Below a few points, the EBF and its members underline:
- The appropriateness guidelines as proposed by ESMA are going further than the original idea behind level 1 requirements.
- Information provided to investors should be proportionate as far as the extent of information, means of communication and timing are concerned. one may fear that if too much information and too many details are required from clients, they may be desensitized to invest which would be contrary to CMU overarching objectives.
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