EFAMA is committed to making a constructive contribution to the legislative debate with a view to ensuring that these objectives will effectively be reached in practice and so achieve improved protection for retail investors across the Union. EFAMA strongly believes that the revised IMD provisions should cover the marketing and selling of all types of insurance PRIPs, and that IMD PRIPs should be subject to similar rules as MiFID PRIPs. Therefore, EFAMA welcomes Article 1 paragraph 3a of the MiFID II text which has been voted in the European Parliament on 26 October, 2012.
EFAMA welcomes that the definition of an IMD PRIP is not standalone but cross refers to the PRIP definition in the proposed KID Regulation. However, it is also important that the MiFID inducement rules and the IMD inducement rules should be aligned. EFAMA therefore urges that these provisions be debated in parallel.
Also, in order to achieve a level playing field across the industry and products, EFAMA strongly believes the date of entry into force of IMD II should be consistent with the date of entry into force of MiFID II. Furthermore, "the whole of the market" should be defined as all IMD and all MiFID PRIPs. As they stand, the separate MiFID and IMD proposals would result in two separate markets, which would not be in the interests of retail investors and would be counter to the objectives of the overall PRIPs initiative.
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