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By Dr. Sebastiaan Niels HOOGHIEMSTRA, Loyens Loeff*
As part of the EU Retail investment strategy, the European Commission (“EC”) published on 24 May 2023 a proposal (the “RISD”) to amend, amongst others, Directive 2011/61/EU, as amended (“AIFMD”), Directive 2009/65/EC, as amended (“UCITSD”) and Directive 2014/59/EU, as amended (“MiFID II”). One of the topics of the proposal that have received recently a lot of attention is the one on “value for money”, i.e. new rules that include a new pricing process that is proposed to be integrated in the product governance frameworks of both “manufacturers” and distributors. The intention of the rules is to limit the offer of “products” that bear poor or no “value for money” for (retail) investors.
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