Maurizio Prianni on Bluerating: “More courage doesn’t hurt”

One year after its presentation by the Commission (it was 24 May 2023), the omnibus Retail Investment Strategy (RIS) directive, which will reform Mifid 2, Idd, Ucits, Aifmd and Solvency 2, has not been voted on from Parliament on 23 April. The Assembly did not accept the amendments that had been presented on 2 April by Econ (Parliament’s standing committee on economic and monetary affairs) and decided to start interinstitutional negotiations with the Commission and the Council to prepare a shared text to be submitted to vote. It will certainly go to 2025.

Some observers have pointed the finger at the European elections (scheduled for 6 to 9 June in the 27 member states), others have criticized the obstinacy of the lobbies and the assiduous criticism of professionals: from consultants to industry to trade associations; among the latter, it is worth mentioning that of Efama (European Fund and Asset Management Association), which recently proposed replacing the benchmarks envisaged by the RIS to weight the value for money with an analysis based on peer groups. I believe that the difficulty of the birth is also linked to the height of the ambition: to make European citizens aware investors, to push them to use their savings in the European capital markets and in the real economy, to make them protagonists of the growth and development of the Union.

In other words: catching up with what is already happening in the United Kingdom and the United States. The framework of the RIS goes in this direction, undoubtedly through its four fundamental pillars: incentives, customer best interest, value for money of the products and benchmarks, which are unlikely to be changed compared to the first proposal of the European Commission.

Ready to operate

As proof of this, numerous market operators have been preparing for some time to be ready to operate according to the new principles. Not only that, in some cases the RIS indications are already in some way in force and implemented. Let’s think, for example, of what is foreseen by our IVASS with the recent provisions on financial insurance products (IBIPs), which must be created on the basis of models that demonstrate the value for money for customers. We should also reflect on the dissemination of ESMA benchmarks among operators to monitor the performance and costs of investment products.

We need to do more

Prepare to make the most of RIS opportunities. Whether the incentives are maintained or not (as is known, the most controversial topic of the reform), it will be useful to reflect on the paid consultancy offer, to be offered to customers in synergy with the value for money principle of the products.

Contraction possible

Value for money, among other things, will probably lead to a contraction of the range to be offered to customers, not just the richest ones, with logic increasingly based on customization with respect to specific needs and desires. Best interest will have to lead operators to increasingly consider the particular interests of customers, to be broken down into expected performance, time horizons, risk profile and coupon flows. Ultimately, the benchmarks will stimulate transparency, improve competition and optimize the entire sector as a whole.


L’Istituto del “Whistleblowing” è riconosciuto come strumento fondamentale nell’emersione di illeciti; per il suo efficace operare è pero cruciale assicurare una protezione adeguata ed equilibrata ai segnalanti. In tale ottica, al fine di garantire che i soggetti segnalanti siano meglio protetto da ritorsioni e conseguenze negative, e incoraggiare l’utilizzo dello strumento, in Italia è stato approvato il D.Lgs. n.24 del 10 marzo 2023 a recepimento della Direttiva (UE) 2019/1937 riguardante la protezione delle persone che segnalano violazioni.

Il decreto persegue l’obiettivo di rafforzare la tutela giuridica delle persone che segnalano violazioni di disposizioni normative nazionali o europee, che ledono gli interessi e/o l’integrità dell’ente pubblico o privato di appartenenza, e di cui siano venute a conoscenza nello svolgimento dell’attività lavorativa.


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