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FESE welcomes the opportunity to contribute its views to the EIOPA consultation on the methodology for Value for Money (VfM) benchmarks. In its response, FESE stresses the need for a clear focus on “cost-efficiency” when constructing the benchmarks. FESE reiterates that the cost should not be the main indicator when developing the VfM benchmarks and that the ESAs should consider other qualitative factors, such as the distribution channel of retail products.”