In its position paper regarding the MiFID-review of the European Commission Deutsches Aktieninstitut considers improvements with respect to rules concerning investor protection, transparency, research, commodity derivative markets and FX-spot transactions.

Deutsches Aktieninstitut comments the ESA's consultation paper on PRIIPs and points out that corporate bonds are not in the scope of the respective EU-regulation. As there is a lasting uncertainty in the market clarification by the EU-Commission is necessary.

With regard to the second capital market amendment law Deutsches Aktieninstitut emphasizes not to go beyond the existing European legal provisions, e.g. in the field of the key information document (KID) which have not to be prepared for shares according to the Europen legislation. The same is true for sanctions where the German legislator tends to go beyond the European minimum harmonisation.

In order to promote public equity financing and equity culture in Germany Deutsches Aktieninstitut suggests to implement the recommandations developed by the round table initiated by the economics minister Gabriel as soon as possible.

The position paper comments the draft regulation on "key information documents for packaged retail products". The intention of the EU-parliament to extend the scope of the regulation on corporate bonds would have negative impacts. A key information document for corporate bonds does not provide additionally benefits for retail investors. Nevertheless, its preperation is very burdensome for issuers. As a result attractiveness of capital market financing decreases.

In 2018, the number of shareholders and investors in equity funds rose by 250,000. This is almost every 6th citizen. In total more than 10.3 million citizens or 16.2 percent of the Germans older than 14 years owned shares or equity funds, reaching the highest leven since 2007.

The number of shareholders and investors in equity funds rised signficantly by 1.1 million to over 10 million in 2017. This equals 15,7 percent of the German population in the age of above 14 years, so that the pre-crisis level has been reached again.

As a result of the increasing regulation more and more banks refrain from providing investment advice for shares. This is the main outcome of a survey conducted among German credit institutions. Due to strict regulatory requirements 22 per cent ceased to provide any advise in shares; 65 per cent reduced its talks - by and large significantly - with customers regarding shares.

The legal obligation to provide a key information document hinders banks to recommend shares to their retail customers. This is the result of a survey conducted by the Deutsches Aktieninstitut among 1,600 German banks. The Deutsches Aktieninstitut therefore asks for a reform of the existing legislation. Instead of a key information document for every share a key information document for the asset class "shares" should be sufficient.