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DA on conduct of business rules for the distribution of insurance-based investment products

Banking and financial services

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Public consultation

ID: 1110

Lobbying Activity

16 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 11 Aug 2017

BEUC is strongly disappointed with the Commission's draft Regulation, which sets the bar on consumer protection lower than proposed by EIOPA. We have been advocating for over 10 years for stronger rules on inducements, which are one of the main sources of consumer detriment in a sector lacking…

Consultation response

Insurance Europe, 16 Aug 2017

Please find attached the Insurance Europe feedback on the DA on conduct of business rules for the distribution of IBIPs.

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 17 Aug 2017

Please find attached the comment of the German Insurance Association (GDV) 6437280268-55

Consultation response

Intesa Sanpaolo, 11 Aug 2017

The group welcomes the European Commission’s delegated acts concerning the Insurance Distribution Directive (IDD). In particular, we support the approach of setting as principles underpinning the advice, the principle of proportionality along with the consistency with MiFID II. These principles…

Consultation response

Allianz SE, 16 Aug 2017

Our recommendation is to align effective dates of the different legal acts regulating insurance distribution (IDD). 2. For both Delegated Regulation (Ref. Ares(2017)3675955 and Ref. Ares(2017)3670050) supplementing Directive (EU) 2016/97 it is stated that it shall apply from 23 February 2018…

Consultation response

Insurance Ireland, 14 Aug 2017

1. Complex Products As currently drafted, one could interpret Article 16 could to mean that only products that offer some form of capital guarantee can be considered ‘non-complex’ under IDD . Based on the wording in the Directive and the preamble of the draft IBIPs Regulation, We do not believe…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 17 Aug 2017

BVI’s comments on the draft Delegated Regulation on conduct of business rules for the distribution of insurance-based investment products As the representatives of the German fund and asset management industry, BVI has been following the IDD negotiations from the onset for reasons of level…

Consultation response

European Federation of Investors and Financial Services Users, 17 Aug 2017

BETTER FINANCE, the European Federation of Investors and Financial Services Users, welcomes this initiative and the opportunity to comment on the Delegated Act on conduct of business rules for the distribution of insurance-based investment products. Retail” financial services are still ranked as…

Consultation response

Associazione Nazionale fra le Imprese Assicuratrici, 8 Aug 2017

With reference to Commission draft Delegated Regulation on information requirements and conduct of business rules applicable to the distribution of insurance –based investment products, please find herewith the comment from Italian Insurance Association (ANIA). We highlight the following point…

Consultation response

Svensk Försäkring, 17 Aug 2017

For feedback, please see attached file.

Consultation response

Verband der Versicherungsunternehmen Österreichs / Austrian Insurance Association, 17 Aug 2017

VVO remarks on the Delegated Act on Insurance-Based Investment Products General comments The recitals mention several times that this delegated act corresponds with the standards set out under MiFID II. However, it should be duly noted that the adoption of a sectoral insurance distribution…

Consultation response

Fédération Européenne des Conseils et Intermédiaires Financiers, 4 Aug 2017

FECIF appreciates that the proposal for the Delegated Act is consistent with the text of the IDD. To combine the three empowerments on additional conduct of business requirements for IBIPs into one delegated act is a clever move by the Commission and will make it easier for our members, the…

Consultation response

CNCEF Patrimoine, 17 Aug 2017

If we agree that manufacturers shall continuously monitor and regularly review insurance products they have brought to the market, shall identify issues and take appropriate action, we consider that they couldn’t systematically inform customers about the remedial action taken as they might have no…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 17 Aug 2017

Please find attached BIPAR comments on the IDD DA on conduct of business rules for the distribution of insurance-based investment products (IBIPs)

Consultation response

Bund der Versicherten e.V., 17 Aug 2017

We fully agree with the assessment of the Commission that insurance-based investment products are often sold as potential alternatives or substitutes to retail investment products. We clearly reject that the reference to monetary benefits (such as inducements) has been removed from the list of…

Consultation response

Association of International Life Offices, 16 Aug 2017

The Association of International Life Offices (“AILO”) comments on DA on conduct of business rules for the distribution of insurance-based investment products Article 16 AILO has two major concerns regarding criteria for a non-complex IBIP. There is a complete lack of alignment with PRIIPs…