Response to joint Comitteee Discussion Paper on automation in financial advice

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1. Do you agree with the assessment of the characteristics of automated financial advice tools presented in this Discussion Paper? If not, please explain why.

We fully support EFAMA's answer

2. Are there any other relevant characteristics of automated financial advice tools?

We fully support EFAMA's answer

3. Are you aware of examples of automated financial advice tools being used in the banking, insurance, and/or securities sectors? Please provide examples, giving details of their operating process.

We fully support EFAMA's answer

4. Do you offer/are you considering offering automated financial advice tools as part of your business model? If so, please briefly describe: i) what type of entity you are, e.g., long established, start-up, a product provider, an intermediary; ii) the service you provide (e.g. to what extent do you integrate human interaction in the tool you provide?); iii) the nature of your clients; iv) your business model; v) who developed the automated tool (i.e. an external company or developed internally?); and vi) the size of your activity and/or forecast activity?

5. Do you consider there are barriers preventing you from offering/developing automated financial advice tools in the banking, insurance and securities sectors? If so, which barriers?

We fully support EFAMA's answer

6. Do you consider the potential benefits to consumers to be accurately described? If not, please explain why.

We fully support EFAMA's answer. We have observed in the French market that most automated advisors do propose a human contact over the phone in order to better assist the investor.

7. Are you aware of any additional benefits to consumers? If so, please describe them.

We fully support EFAMA's answer

8. Do you see any differences in the potential benefits arising for consumers in each of the banking, insurance and securities sectors?

We fully support EFAMA's answer

9. Have you observed any of these potential benefits to consumers? If so, please provide examples and describe the kind of benefit that has accrued.

We fully support EFAMA's answer

10. Do you consider the potential benefits to financial institutions to be accurately described? If not, please explain why.

We fully support EFAMA's answer

11. Are you aware of any additional benefits to financial institutions? If so, please describe them.

We fully support EFAMA's answer

12. Do you see any differences in the potential benefits arising for financial institutions in each of the banking, insurance and securities sectors?

We fully support EFAMA's answer

13. Have you observed any of these potential benefits to financial institutions? If so, please provide examples and describe the kind of benefit that has accrued.

We fully support EFAMA's answer

14. Do you agree with the description of the potential risks to consumers identified? If not, explain why.

We fully support EFAMA's answer

15. Do you consider there to be any risks to consumers missing? If so, please explain.

We fully support EFAMA's answer. To limit risks to consumers, in France, some automated advisors are created with the status of asset management company, and as such are closely regulated. For example, they perform on-going services with regular reviews with their clients.

16. Do you see any differences in the potential risks arising for consumers in each of the banking, insurance and securities sectors?

We fully support EFAMA's answer

17. Have you observed any of these risks causing detriment to consumers? If so, in what way?

We fully support EFAMA's answer

18. Do you agree with the description of the potential risks to financial institutions identified? If not, explain why.

We fully support EFAMA's answer

19. Do you consider there to be any risks to financial institutions missing? If so, please explain.

We fully support EFAMA's answer

20. Do you see any differences in the potential risks arising for financial institutions in each of the banking, insurance and securities sectors?

We fully support EFAMA's answer

21. Have you observed any of these risks causing detriment to financial institutions? If so, in what way?

We fully support EFAMA's answer

22. Would you agree with the assessment of the potential evolution of automated advice? Please provide your reasoning.

We fully support EFAMA's answer

23. How do you think that the market for automation in financial advice will evolve in the near future in the banking, insurance and investment sectors? Please also provide details of any relevant data or information to support your views, where available.

We fully support EFAMA's answer

24. Are there any other comments you would like to convey on the topic of automation in financial advice?

We fully support EFAMA's answer

Name of organisation

AFG -Association Française de la Gestion Financière

Organisation and governance

Legal and policy framework

Supervisory convergence

Direct supervision and oversight

Information for consumers

Ad hoc activities

Risk analysis

Reporting frameworks

Data

Publications

Media centre

Response to joint Comitteee Discussion Paper on automation in financial advice

1. Do you agree with the assessment of the characteristics of automated financial advice tools presented in this Discussion Paper? If not, please explain why.

2. Are there any other relevant characteristics of automated financial advice tools?

3. Are you aware of examples of automated financial advice tools being used in the banking, insurance, and/or securities sectors? Please provide examples, giving details of their operating process.

5. Do you consider there are barriers preventing you from offering/developing automated financial advice tools in the banking, insurance and securities sectors? If so, which barriers?

6. Do you consider the potential benefits to consumers to be accurately described? If not, please explain why.

7. Are you aware of any additional benefits to consumers? If so, please describe them.

8. Do you see any differences in the potential benefits arising for consumers in each of the banking, insurance and securities sectors?

9. Have you observed any of these potential benefits to consumers? If so, please provide examples and describe the kind of benefit that has accrued.

10. Do you consider the potential benefits to financial institutions to be accurately described? If not, please explain why.

11. Are you aware of any additional benefits to financial institutions? If so, please describe them.

12. Do you see any differences in the potential benefits arising for financial institutions in each of the banking, insurance and securities sectors?

13. Have you observed any of these potential benefits to financial institutions? If so, please provide examples and describe the kind of benefit that has accrued.

14. Do you agree with the description of the potential risks to consumers identified? If not, explain why.

15. Do you consider there to be any risks to consumers missing? If so, please explain.

16. Do you see any differences in the potential risks arising for consumers in each of the banking, insurance and securities sectors?

17. Have you observed any of these risks causing detriment to consumers? If so, in what way?

18. Do you agree with the description of the potential risks to financial institutions identified? If not, explain why.

19. Do you consider there to be any risks to financial institutions missing? If so, please explain.

20. Do you see any differences in the potential risks arising for financial institutions in each of the banking, insurance and securities sectors?

21. Have you observed any of these risks causing detriment to financial institutions? If so, in what way?

22. Would you agree with the assessment of the potential evolution of automated advice? Please provide your reasoning.

23. How do you think that the market for automation in financial advice will evolve in the near future in the banking, insurance and investment sectors? Please also provide details of any relevant data or information to support your views, where available.

24. Are there any other comments you would like to convey on the topic of automation in financial advice?

Name of organisation