EUSIPA focuses its response rather on general concerns arising from technical consultations on complex market aspects as the one in question here aiming to better understand retail investor behaviour, which would realistically require a profound and time-consuming analysis in qualitative and quantitative regard. Particular emphasis is being given to the absence of any apparent linkage of this consultation to major legislative projects such as the Retail Investment Strategy. EUSIPA finally makes recommendations to avoid such situations in the future.
The full EUSIPA statement can be found under below link.