FECIF - The European Federation of Financial Advisers and Financial Intermediaries
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Editorial - September 2018

Daphne FoulkesDaphne Foulkes,
Chairperson of FEPI, Board Member of FECIF and Partner at The Spectrum IFA Group

Next step for the PEPP saga

To date, many organisations have submitted detailed responses to the European Commission’s (EC) draft PEPP Regulation, which was published on 29th June 2017. There is strong consensus for the merit of the PEPP, both by the Trilogue participants (European Commission, European Parliament and the Council of Europe) and other stakeholders. However, potential obstacles still exist and, unless pragmatic solutions are found, there is the risk that the PEPP could be launched but the take-up may be low.

Therefore, as the PEPP enters its next stage of Trilogue discussions, it is important that the voices of the potential PEPP providers and distributors are still heard, since these stakeholders are well-placed to highlight practical difficulties that would adversely affect the success of the PEPP. A cross-section of these stakeholders came together at the FECIF European Pensions Institute’s (FEPI) inaugural meeting in June. A FEPI position paper has subsequently been produced, which provides detailed analysis, whilst a brief summary of the FEPI’s views is shown below.

  • Tax Incentives: It is very important that a pragmatic alternative solution be agreed by the Trilogue, rather than being left until after the Regulation has been enacted. Theoretically, a fully separate tax regime – i.e. a 29th regime – applicable across all of Europe would be ideal in terms of simplicity and portability. However, it is understood that this is not likely to be accepted by Member States.

    Therefore, the FEPI recommends that sub-sections can initially be limited to EET (exempt/exempt/taxed) and TEE (taxed/exempt/exempt), as these would align with the majority of Member States’ local taxation rules. If desired, EEE & TTT sub-sections might also be created for alignment with other Member States, as demand arises. Obviously, the tax regime applicable to any PEPP participant is based on the participant’s tax residency, as is the case for all retirement products today, backed up by the rules of existing Double Taxation Agreements.
     
  • Default Investment Option: Two possibilities are now on the table:
     
    • A nominal ‘guarantee on capital’, to cover at least the contributions paid (net of fees and charges) as a minimum, which can be extended by the PEPP provider to include inflation protection.
    • An ‘investment strategy directed at ensuring capital protection of the saver on the basis of a risk mitigation technique’ – more simply known as a life-cycle approach

    The opinion of the FEPI is that the PEPP framework should allow for both of the above, if necessary shaped at a local level, according to national rules or custom. As detailed in the FEPI position paper, the guarantee on capital should be real (not nominal). In addition, there is merit in using life-cycle investing as the basis for a default option for retirement planning, even for investors that may have a more cautious attitude to investment risk, depending upon the time horizon of the investor.

  • Decumulation Options: Whilst a single regime for the PEPP would be ideal in terms of simplicity and portability, it is understood that this could present issues for Member States if, for example, this resulted in the PEPP being granted a more favourable treatment than a local Personal Pension Product (PPP). Likewise, if a local PPP had more favourable treatment than the PEPP, this would serve as a deterrent for someone investing in a PEPP.

    Therefore, the general consensus of the FEPI is that within the framework of the PEPP, decumulation options should be broad, covering all potential pay-out variations, allowing for PEPP providers to shape the PEPP according to local rules.
    Notwithstanding the above, the more complex the product, the greater the costs of administration, which will directly impact on the investment returns to the consumer and so an appropriate balance must be found.
     
  • Distribution & Advice: It is arguable that PEPPs should only be sold on an advised basis, even if the saver has chosen the default investment option – whether this be a real capital guarantee or a lifecycle investment option. The impact of national pension entitlements, varying decumulation options and retirement ages, particularly if the PEPP saver has cross-border accumulated benefits, strengthens the need for the PEPP saver to receive appropriate advice, regardless of the amount being saved.

    At the very least, the requirement for an appropriateness test should be a pre-requisite in all situations, as a minimum level of saver protection is always necessary. Decisions concerning pension products are numbered amongst the most important that each saver is expected to make in his/her life.

The question now is will the Trilogue be able to reach a consensus on the PEPP that is acceptable to all stakeholders?

Due to the importance of the PEPP, a round table will take place at FECIF’s forthcoming Annual Conference taking place on Wednesday, 17th October 2018 at the Renaissance Brussels Hotel, Belgium. This is a major event and, amongst other issues, will address two significantly important and relevant areas:

  • Personal retirement planning across the EU, not least the Pan-European Pension Plan
  • The rise, development, importance and future role of Fintech

The event will ask, and look to answer, numerous key questions, such as: how can we stimulate private pension provision and motivate consumers to take personal responsibility for their financial futures; can the PEPP provide a solution and is a truly pan-European pension possible; can Fintech assist in these areas and, if so, how?

Speakers and participants will be key individuals from EU regulatory bodies and consumer associations, academics and MEPs, as well as numerous major industry figures.

 If you are interested in sponsoring or attending this event, please email: fecif@skynet.be .

 

 

 

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Editorial - August 2018

Vincent J.DerudderVincent J.Derudder
Honorary Chairman

Crisis in Europe?

Europe is going through a very serious crisis and so is the EU financial services industry.

To focus on some basic indicators, the world today is made up of a homogenous block of four dominant countries (the US, Russia, India and China) representing 4 billion people and..

>> CONTINUE READING

Editorial - July 2018

David CharletDavid Charlet
FECIF & ANACOFI Chairman

What sort of summer for intermediaries and Europe?

And now comes the time for holidays for most citizens in Europe, but also time for everyone in their offices to have a couple of quieter weeks, dedicating their work to more fundamental tasks like reviewing their processes or closing late files that...

>> CONTINUE READING

Editorial - June 2018

Jirí ŠindelárJiří Šindelář
Deputy Chairman FECIF

Did we become hostages to ever-increasing regulation?

According to most common sources, Stockholm syndrome is a type of psychological bond between hostage and their hijacker, when the former develops emotional ties to a person that beats, abuses or generally hurts him or her. Plainly sad, it is....

>> CONTINUE READING

Editorial - April 2018

Vania FranceschelliVania Franceschelli
Member of Fecif Board of Directors & Foreign Affairs, Anasf

IDD and MiFID II. Beloved sisters or competing friends?

Time has come. On 19 March the amendment postponing the application date of directive 2016/97 (Insurance Distribution Directive - IDD) has been published in the Official Journal of the European Union. By 1 July Member States shall thus adopt and publish all the laws...

>> CONTINUE READING

Editorial - February 2018

Daphne FoulkesDaphne Foulkes,
Partner, The Spectrum IFA Group and FECIF Board Member

Will your pension sustain you through retirement?

It is widely known that Europe’s ageing population is a problem for EU Member States. Quite simply, people are living longer and this impacts on the sustainability of State pension systems, referred to as...

>> CONTINUE READING

Editorial - December 2017

David CharletDavid Charlet
FECIF & ANACOFI Chairman

Beyond robo-advisors, what might the future be for following generations?

The media seems to have only one word to say at present, when explaining our future: robots! Is it time for robo-advisors to replace our human members?
If you take a look to some of our previous editorials, written by our Secretary General or some of our members, you will...

>> CONTINUE READING

Editorial - October 2017

Dhruv MehtaDhruv Mehta,
Chairman of the FOUNDATION OF INDEPENDENT FINANCIAL ADVISORS

Evolution and Regulatory Challenges – Lessons from India

The Foundation of Independent Financial Advisors (FIFA) is a body representing Advisors and Distributors of Mutual Funds in India, commonly known as Independent Financial Advisors (IFAs).
During my recent meeting with FECIF I realised the common vision that both associations have for their members...

>> CONTINUE READING

Editorial - August 2017

Jirí ŠindelárJiří Šindelář
Member of FECIF board of directors

How Vox Populi in Europe is (sometimes) being portrayed

Two weeks ago, my home city of Prague hosted an important event: the Joint ESAs’ Consumer Protection Day. This is an event that forms an important part of the regulation agenda and according to its organisers should “discuss issues related to consumer...

>> CONTINUE READING

Editorial - June 2017

David CharletDavid Charlet
FECIF & ANACOFI Chairman

Europe as financial advisers see it

A long time ago, the European Union used to be a place for the production of coal and steel. Nowadays, it seems to be a global Union far more engaged than the US with our jobs and other matters. Consider: in the US no would find “passports” for...

>> CONTINUE READING

Editorial - April 2017

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Are you really ready for the future?

“The other day Ray was having a conversation with his 13 year old son and they ended up on a topic / issue that they needed more info on – his response was to “Google” it, his son chose to “YouTube” it. He realised at that point that they had different ways of looking for information, learning answers, and engaging with...

>> CONTINUE READING

Editorial - February 2017

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Transparency not commission is the real key for 2017 and beyond

A number of industry commentators keep stating that it’s now all about the end of commission on a global basis – but is it, really? We all know of the switch to fees in the UK, and also a small number of other locations around the world, but certain other jurisdictions have also been quoted as moving in that direction, only for regulators in...

>> CONTINUE READING

Editorial - December 2016

Paul ResnikPaul Resnik
Cofounder & Director of Finametrica

Robo 3.0

Robo advisors are, beyond any doubt, hugely disruptive to the financial advice market. But not in the way that many people expect.

Many commentators and analysts are still focused on trying to pick the ‘Uber moment’, when robos wipe out the old world by...

>> CONTINUE READING

Editorial - October 2016

Schroders Investment ManagementSchroders Investment Management

Over confident investors and the help they need

Investors thinking they know more than they do about investing could cause problems when it comes to their future financial planning.

Investors could be missing out on billions of Euros in investment returns by over estimating their own ability to understand...

>> CONTINUE READING

Editorial - August 2016

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Robo-advice financially unviable

The above was the main content of an article in a financial industry publication last month. This was based on a recent study, which found that UK robo-advisers are structured in such a way that they will lose money and “most will go bust before acquiring the sizeable assets under management needed to survive”.

Food for thought, not least for regulators – many of whom seem...

>> CONTINUE READING

Editorial - June 2016

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Do consumers and advisers finally have the same goals?

Over the last year or two it has struck me that the increasing complexity of regulation is not only being seen in a negative light by the financial advisory and intermediary market – there are also growing concerns being expressed by consumers and, in particular, consumer groups, that this is having a negative impact on the public at large.

>> CONTINUE READING

Editorial - April 2016

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Interesting implications for the rest of Europe and beyond?

Last month saw the publication of the results for the UK’s Financial Advice and Market Review (FAMR). Whilst this might not have had much in the way of impact elsewhere across Europe, it perhaps should have done...

>> CONTINUE READING

Editorial - February 2016

Jirí ŠindelárJiří Šindelář
Member of FECIF board of directors

The Brussels’ Circle of Overregulation

Even though the European Union was given a series of warnings regarding its effort to regulate anything and everything, it did not slow down. Despite proclamations about “changing the course” and “smart regulation”, from November to December...

>> CONTINUE READING

Editorial - December 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Robo-advice: fact and fiction

I have lost count of the amount of articles about so-called robo-advice. It certainly is the “flavour of the month” and, if we believe all that we hear, will soon become the most important element in the delivery of financial services. I have some strong views on this….

>> CONTINUE READING

Editorial - October 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Where now for commissions?

European regulators eventually “stood back from the brink” and within the agreed text of both MiFID 2 and the IDD (Insurance Distribution Directive) fell short of a complete commission ban – a ban that many thought might well happen as little as 12 months ago!...

>> CONTINUE READING

Editorial - August 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

The importance of effective representation

The compromise text for the Insurance Distribution Directive (IDD) was recently finalised and it was very pleasing to see that the vast majority of the proposals put forward by FECIF in the recent consultation period have been heeded.

>> CONTINUE READING

Editorial - June 2015

Garry HeathGarry Heath
Director General Libertatem

Garry Heath announced the launch of Libertatem last month, a new trade association set up to represent all types of financial advisers based in the UK. His thoughts and plans are outlined below – they have great relevance to the rest of Europe.

Over the last decade the industry has lost sight ...

>> CONTINUE READING

Editorial - April 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

10 reasons to use a Financial Adviser

Many people have the perception that only the very wealthy need financial advice. However, the facts are that anyone can potentially benefit from such advice...

>> CONTINUE READING

Editorial - February 2015

Garry HeathGarry Heath
Journalist, The Heath Report assured

IFAs: Support trade associations or jeopordise independence

The last month has been one of travel. Firstly a symposium to address in Toronto and then it was Brussels and the FECIF conference...

>> CONTINUE READING

Editorial - September 2014

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Our immediate goals

I was very pleased to be elected as the new Secretary General of FECIF at our last Board meeting, it is very much an honour to represent a body that supports and promotes the adviser...

>> CONTINUE READING

Editorial - June 2014

Paul StanfieldPeter Brooke
Financial Planner, member and partner with the Spectrum IFA Group

Should I use a Financial Adviser to help me?

Creating a financial plan is NOT a complicated thing to do; it is an audit of where you are today, financially, and where you want to be at different stage...

>> CONTINUE READING

Editorial - May 2018

Simon ColbocSimon Colboc
Member of Fecif Advisory Committee

The PEPP saga: what does it mean for advisors?

Anyone interested in the future of pensions should welcome the European initiative on the Pan European Personal Pension products (PEPP). Retirement provision is a major issue facing all European countries, hit by a combination of increasing...

>> CONTINUE READING

Editorial - March 2018

Jirí ŠindelárJiří Šindelář
Deputy Chairman FECIF

How much do we pay for over-regulation?

Over-regulation of financial services in the European Union is a well-recognised fact, even among the bureaucracy in Brussels. The key feature of all those MiFIDs, IDDs or GDPRs, however, is not its devastating effect on the (small and medium-sized) businesses themselves, but its detrimental cost to the customer...

>> CONTINUE READING

Editorial - January 2018

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

The moment I realised the value of (human) advice

This was (almost) the title of an article I recently read – and which reminded me of the fact that many advisers don’t always realise just how much positive impact they have on people’s lives. Or where that impact is most beneficially experienced by the client...

>> CONTINUE READING

Editorial - November 2017

Vania FranceschelliVania Franceschelli
FECIF Board Member and Regional Manager of the ANASF financial education programme

The social value of financial education

If I consider my personal experience as a financial advisor and, more generally, the provision of investment services to citizens, I can envisage two concepts for the future of our professional activity: investor protection and financial education. On the one hand, investor...

>> CONTINUE READING

Editorial - September 2017

Daniel GuéguenDaniel Guéguen
Head of Strategy and Lobbying at PACT European Affairs

A journey through the EU Institutions

Every year before the start of the summer break, I treat myself to a journey through the EU Institutions. I say ‘treat’ because it is a real pleasure for me to speak freely and in full confidence with elected politicians, senior civil servants, head lobbyists and representatives from...

>> CONTINUE READING

Editorial - July 2017

Vania FranceschelliVania Franceschelli
FECIF Board Member & ANASF Executive Committee Member

Product governance requirements will lead to greater quality of advice

Product governance requirements represent one of the most outstanding innovations of MiFID II, aiming at ensuring that firms which manufacture and distribute financial instruments act in the clients’ best interests during all the stages...

>> CONTINUE READING

Editorial - May 2017

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

The value of advice – and the cost of being unadvised

There have been numerous studies over the years that have shown the value of good quality financial advice – not least, the fact that clients that receive it are, in general, significantly better off in retirement and much more financially protected during their life journey towards that point...

>> CONTINUE READING

Editorial - March 2017

Vania FranceschelliVania Franceschelli
FECIF Board Member & ANASF Executive Committee Member

We need new market propositions not unnecessary bans

The final date for the transposition of MiFID II in each Member State – January 3rd 2018 – is fast approaching. Is it possible to see some initial insights into the industry, in order to foresee the impact of the Directive on business models? In particular...

>> CONTINUE READING

Editorial - January 2017

Daniel GuéguenDaniel Guéguen
Head of Strategy and Lobbying at PACT European Affairs

2017: action, action, action

”My right flank is destroyed, my left flank is in retreat, everything is fine – attack!” Those were the words of General Foch in the darkest moments of World War One. We are there once again. Sink or act – that is the choice we have.

>> CONTINUE READING

Editorial - November 2016

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Playing your Trump card

Well, for those of us surprised by the Brexit vote - and there were plenty in the City of London that is for sure – the US election creates a whole new perspective with regards to astonishment, and on a much wider spectrum. I don’t know what it says about Hillary Clinton and her campaign – well, on reflection, I probably do – but the fact that Trump won, allied to the UK’s EU...

>> CONTINUE READING

Editorial - September 2016

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

“The reports of my death have been greatly exaggerated”

This famous quote was a statement made by Mark Twain on hearing that he had been mistakenly announced dead. Although it is apparently a slight misquote, the meaning remains very much in line with what the great writer intended. It also came to my mind the other day when I was once again thinking about so-called “robo-advice” and...

>> CONTINUE READING

Editorial - July 2016

John WestwoodJohn Westwood
FEIFA Board Member and Blacktower Group Managing Director

Brexit: a disaster or something far less worrying?

The British electorate has given its verdict on the UK’s membership of the European Union in no uncertain terms but, in spite of some emotional appeals to the contrary, this is not a disaster.

It is worth remembering that on the 20th February 2016, when David Cameron announced that the EU referendum would...

>> CONTINUE READING

Editorial - May 2016

Rebecca MurphyRebecca Murphy
Director of Sales & Marketing at Praemium
Re-engaging the investor

Re-engaging the investor

It’s rough sailing right now for investors and savers alike! Volatile markets and low interest rates are the norm, and investors are bombarded with information about products and services without understanding how any of it relates to them...

>> CONTINUE READING

Editorial - March 2016

David DentonDavid Denton
Member of FECIF board of directors

You can run, but you can’t hide

The Organization of Economic Cooperation and Development’s (OECD) Common Reporting Standards (CRS) - also known as Automatic Exchange of Information - is gathering pace post FATCA. For decades, developed economies have wrestled with the notion that wealth overseas, whilst not illegal...

>> CONTINUE READING

Editorial - January 2016

Hans-Jürgen BretzkeHans-Jürgen Bretzke
CEO of FinanzAdmin  GmbH

Some of the myths surrounding fintech companies

“I would go so far as to say that any broker armed with an average customer base and network is better placed than a fintech company on the strength of his or her client contacts alone.”

In this guest contribution, Hans-Jürgen Bretzke, a member of ...

>> CONTINUE READING

Editorial - November 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Pension provision - is this the real “gap”?

The “advice gap” has received considerable coverage in the personal finance pages and trade press for some time now, across the UK in particular but it is also a growing concern across Europe and beyond. I wonder, however, if the focus should really be on the “pension’s gap”...

>> CONTINUE READING

Editorial - September 2015

Vania FranceschelliVania Franceschelli
Member of the Board of FECIF / Member of the Executive Committee of ANASF (Head of Foreign Affairs)

In July FECIF sent its contribution to the ESMA Consultation Paper on the Draft guidelines for the assessment of staff knowledge and competence under MiFID II. This Consultation Paper is of outmost importance for all financial advisors in Europe, as it provides the basis for the definition of the qualification and...

>> CONTINUE READING

Editorial - July 2015

Paul StanfieldPaul Stanfield
Chief Executive at FEIFA / FECIF Secretary General

Making regulation more effective and accountable

The month of May saw the launch of a new trade association in the UK, as highlighted in last month’s editorial. It seems to me that its aims and concerns are highly important elsewhere in the EU.

>> CONTINUE READING

Editorial - May 2015

Johannes MuschikJohannes Muschik
Chairman of FECIF, Chairman of AFPA

New Chairman takes office

Back to my desk after our Annual General Meeting where I have been elected as Chairman for the period 2015/2016.  The AGM was also an opportunity to exchange views on a number of hot topics concerning our industry...

>> CONTINUE READING

Editorial - March 2015

Jirí ŠindelárJiří Šindelář
Chairman of USF CR / Member of the board of FECIF

Squaring the circle, or back to roots? A view of European regulatory turmoil from the former “Eastern Bloc”

When the Velvet revolution overthrew the Czech communist government in 1989, a crucial part of the change was the transition to liberal...

>> CONTINUE READING

Editorial - December 2014

Graham ReidGraham Reid
Managing Director at Classic Financial Solutions CVBA

The true worth of an adviser

A few years ago one of our clients suffered a nervous breakdown.  After early retirement he had continued working as a consultant from a small office at home, from where he also managed the family finances, something in which ...

>> CONTINUE READING

Editorial - July 2014

David CHARLETDavid CHARLET
ANACOFI

For my first editorial as President of FECIF, I would like to thank every member of the Board, the General Assembly and the Staff.
I would also express a special thought for Daniel Nicolaes, one of the best representatives of our profession in Europe, who disappeared a few months ago.

>> CONTINUE READING

 

 

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