EFAMA believes that the general assessment of the characteristics of automated financial advice tools is captured accurately.
Nevertheless, we take note of the ESAs’ very broad understanding of “advice” which not only encompasses the definitions of “advice” from the relevant existing sectorial legislations but also blurs this with the retail consumers’ common perception of advice. It is important that this confusion is addressed. The ESAs should ensure a common terminology to describe financial advice rather than the confusing definitions of advice (pension advice, mortgage advice, investment advice, simplified advice, guidance, etc.) with different requirements and liabilities.