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Editorial

FECIF Editorial

FECIF Editorial

our policy-focused commentary written monthly by FECIF board members and industry experts, offering expert perspectives on regulatory developments, industry challenges, and opportunities that affect financial intermediaries across Europe.

our policy-focused commentary written monthly by FECIF board members and industry experts, offering expert perspectives on regulatory developments, industry challenges, and opportunities that affect financial intermediaries across Europe.

We must recognize the indispensable role of professional intermediaries, stop treating financial advice as a liability, and start seeing it as a cornerstone of participation and trust.
Martin Klein
Martin Klein
Martin Klein

Martin Klein

Vice Chairman of the FECIF Board

Martin Klein
VOTUM
Martin Klein
VOTUM
Martin Klein
VOTUM
Editorial | April 2025
Editorial | April 2025

Ensuring fair access to Insurance and Financial Services for Seniors

by Martin Klein, Vice Chairman of the FECIF Board, VOTUM Chairman

Those who wish to strengthen retail participation in capital markets must not build regulatory barriers to entry. Yet current developments in Brussels suggest a growing risk of precisely that. Two legislative initiatives are currently under the spotlight: the Retail Investment Strategy (RIS) and the Framework for Financial Data Access (FIDA). Both aim to reshape key aspects of the European financial market architecture – but with vastly different objectives and implications.

Retail Investment Strategy: Well-Intended but Ill-Designed

The declared aim of the RIS is to empower retail investors and mobilize private capital to stimulate economic growth. A legitimate goal, in principle. But the way the legislative process is unfolding tells a different story. The ongoing trilogue negotiations have reached an impasse, with three divergent texts from the European Commission, the Council, and the Parliament confronting each other – some with fundamental contradictions.

According to Members of the European Parliament, the current trilogue represents an unprecedented situation: for the first time, both Council and Parliament have formally rejected the Commission's original draft, jointly urging the Commission to revise and simplify its own proposal. A six-week deadline was set for this task. In response, the Commission – visibly irritated – has indicated it may withdraw the proposal altogether if no agreement is reached in the next round. This level of confrontation is virtually unheard of in the history of European legislative negotiations.

Substantively, this escalation is not without reason. The current RIS draft falls far short of its promise. If we are serious about transforming savers into investors, we must also offer them meaningful support. Bans on advice and excessive layers of documentation lead not to empowerment, but to overload, insecurity, and retreat. Especially when it comes to long-term and complex products – such as infrastructure or real estate – professional guidance is indispensable. That support comes at a cost and must be properly acknowledged and enabled by regulation.

A policy that isolates investors and weakens intermediaries while championing disclosure for its own sake will not drive capital into the markets. What we need instead is a more pragmatic integration of RIS into the broader framework of the Savings and Investment Union – one that reflects the realities of the market and the vital role of advisory services.

FIDA: Sharing Data – But with Perspective

FIDA is of a different nature. Its aim is not to foster investment directly, but to lay a regulatory foundation for how financial data can be accessed and exchanged. At its core, the initiative seeks to improve transparency and product comparability – especially for retail clients – through standardized, machine-readable data formats. It holds substantial potential not only for retail clients, but also for financial advisers, who would benefit from working with harmonized, high-quality datasets.

In consultations with MEPs, a picture of divided opinion emerges. On the one hand, FIDA could enable innovative business models, support new market entrants, and deliver genuine value through better comparability. On the other hand, serious concerns persist – particularly around data protection, the governance of sensitive personal and advisory information, and the risk of misuse through AI-powered systems that aggregate and repurpose financial data.

One increasingly discussed concern is the potential for regulatory backfire: the fear that high-quality advisory and client data collected within the EU – especially through trusted intermediaries – could be systematically harvested by third-country platforms, most notably from the U.S. Given the superior quality and granularity of European financial data, this is not a trivial risk. It would be deeply counterproductive to build a system that facilitates data flows out of Europe, rather than reinforcing trust and transparency within its borders.

From FECIF’s perspective, FIDA should be approached with neither blind optimism nor blanket resistance. Much will depend on the operational details – on how the current framework is translated into real-world practice. Our stance is clear: the scope of data access must be limited to what is truly necessary. No more, no less. This is the only way to achieve efficiency gains without overwhelming consumers or flooding markets with redundant, low-impact information.

We would also do well to reflect on PSD2. That directive, too, promised a wave of market dynamism and innovation – which never fully materialized. Data does not create markets by itself. It must be managed with care, balance, and clear purpose.

Our Call: Proportional Regulation with Market Relevance

Taken together, RIS and FIDA illustrate the scale of the challenge facing European policymakers today. Ambitious targets collide with the operational reality of market structures, consumer behavior, and intermediary functions. And in this friction lies a risk: that well-meaning regulation may ultimately do more harm than good.

What is needed now is a new realism in the regulatory discourse – less ideology, more pragmatism. We must recognize the indispensable role of professional intermediaries. We must stop treating financial advice as a liability and start seeing it as a cornerstone of participation and trust. And we must ensure that the data economy evolves in a way that empowers consumers, rather than exploiting them.

At FECIF, we will continue to advocate for thoughtful, balanced frameworks – not regulation for its own sake, but policy that genuinely supports capital formation, trust, and financial inclusion.

Donald Trump's influence on financial services in Europe is a little more complex. It could be described currently as creating an indirect rather than a direct existential threat. He is a strong supporter of Wall Street and the markets whilst wanting to curtail the power of overseas corporations in favour of their US competitors. While he may not be a threat to the entire financial sector, there are aspects to his policies and political approach that could create challenges or uncertainties for financial services in Europe.


Martin has been a lawyer in Hamburg since 1997, he specialized in sales law in the area of investments and insurance. He advises companies and intermediaries on the design of their business processes and, as a litigator, represents financial investment intermediaries and insurance brokers in liability proceedings.

Since February 2007, Klein has been responsible for the intermediary association VOTUM, initially as managing director and now as executive director. In this role, he represents the interests of the advisory financial services industry in Berlin and Brussels and is in dialogue with both the relevant ministries and the parties' specialist politicians as part of the ongoing legislative process. The focus of his advisory work is the company-appropriate implementation of European and German regulatory requirements in sales processes. As a member of the supervisory board of brokerage companies, pools and technology providers, he is also involved in shaping the entrepreneurial future of industry companies. He is also involved as a lecturer at the Schmalkaden University of Applied Sciences in training financial service providers.

www.votum-verband.de

Past Editorials

Vania Franceschelli
FECIF Chairperson

Editorial | July 2025

Let Advisers Advise: Clearing the Path to a True Savings and Investments Union

Europe's financial advisers risk getting trapped in a regulatory maze that could stifle the competitiveness we desperately need. While the Commission's simplification…

Josep Soler-Albertí
EFPA Spain’s Executive Director

Editorial | May 2025

Trump Naked, Now What?

Barely three months have passed in his second term, yet it feels like years. With a compulsive media presence and dominating headlines through often…

St John Coombes
St John Coombes

St John Coombes
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Editorial | March 2025

Trump V Europe an existential threat?

The theatre of Donald Trump has caused European leaders to review their current relationships both internally and externally. Whilst the focus to date has been on Global trade and Security the impact of Trump and his GOP allies has been dramatic and direct…

David Charlet
ANACOFI President & FECIF Board Director

Editorial | June 2025

Simplification or Stagnation? The EU’s Regulatory Dilemma

All that for that result ? The European Union has finally realized that it's too cumbersome and not effective enough. It's analyzing and questioning…

Martin Klein, Votum

Martin Klein
Vice Chairman of the FECIF Board

Editorial | April 2025

Between Intention and Reality: RIS and FIDA under Scrutiny

Those who wish to strengthen retail participation in capital markets must not build regulatory barriers to entry. Yet current developments in Brussels suggest a growing risk of precisely that. Two legislative initiatives are currently under…

Cosima F. Barone
Board Member HUB+
Founder & CEO – FINARC SA

Editorial | February 2025

Deregulation in the USA: what about Europe?

As the world awakens to a new reality, i.e., the triumphant return of Donald Trump to the White House, the deregulation process has well begun in the United States. Here's an example of the potential application of an AML rule, brought…