Accessing the petition's related discriminating documents


Accessing the petition’s related discriminating documents #

We are providing PETI with 1300 EU regulated documents that breach EU law because they either discriminate openly against EU US bi nationals and solely US citizens legally residing in the EU or are in breach of EU law because KIDs or PRIIPS KIDs and prospectuses are not consistent with each other as they should be by law.

All aforementioned documents are nonetheless approved by both home state national competent authorities and host state national competent authorities which is another way of saying that those documents are in circulation in 11 EU Member States at least. This vast research explains our request to the European Parliament to order ESMA to investigate said national competent authorities.

Those EU regulated documents are:

  • Prospectuses
  • Marketing material
  • Websites

It goes without saying that with more time and more people we could have unearthed more documents but to make our point as plainly as possible, we checked the documentation of some major asset management companies selling their products in the EU and having received the initial authorization from a home state national competent authorities and was subsequently rubber stamped by host states' national competent authorities.

Our choice of major asset management companies was driven by the fact that we wish to show that this is not anecdotal but that the major players are obviously given license and granted total impunity to discriminate by national and European authorities alike.

The 21 major asset management companies we investigated whose EU financial regulated documentation are in breach of EU law are:

Aberdeen, Aegon, Amundi, AXA, BlackRock, Carmignac, CPR, Crédit Suisse, DWS, ING, JPMorgan, Kempen, L&G, Lazard, Lumyna, Mandarine, Meesman, PrivilEdge, Rivertree, Robeco and Schroders.

In addition, a study of the global websites of major asset management companies selling their products in the EU also show egregious discrimination usually on page one with mentions to the effect that US citizens will not be offered or sold the financial products described on the site.

Among the major asset companies having discriminating websites targeted at EU residents and in all relevant languages are:

Allianz, Amundi, AVIVA, AXA, BlackRock, CPR, DWS, JPMorgan, L&G, PIMCO and Société Générale.

To help PETI and whoever is interested sift through this documentation very rapidly and efficiently we have done the following:

Two recapitulative Excel Sheets detailing in concise form all the discriminating documentation by:

  • The nature of the document (prospectuses, KIDs/PRIIPS KIDs, Websites, marketing materials) and
  • The name of the asset management company issuing such documents and
  • The nationality of the National Competent Authority having authorized such documentation and
  • The countries of circulation of said documents.

We have created an archive with all the discriminating documents that we found. PETI and any person interested have ‘download’ access to this archive, so you can check them yourself.

On the first page of each document (.pdf) you will find a bubble about the relevant page and if needed the discriminating text translated into English.

This should allow PETI to analyze extremely quickly thousands of pages of prospectuses, KIDs, PRIPPS KIDs and Websites to find in a matter of seconds the discriminating mentions in each document.