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30 November 2010

CEA contributes to consultation on EC White Paper on insurance guarantee schemes


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Die CEA argumentiert, dass es keinen Grund für eine EU-Initiative auf Versicherungsgarantiesysteme gäbe, da ein angemessener Schutz der Versicherungsnehmer bereits durch die bestehenden und künftigen europäischen Rechtsrahmen zum Versicherungsmarkt gewährleistet sei.


In its contribution to the European Commission’s consultation on its White Paper on insurance guarantee schemes (IGS), CEA, the European insurance and reinsurance federation, believes that there is no case for an EU initiative on IGS. An adequate level of policyholder protection is already assured through the existing and forthcoming European insurance regulatory framework. Insurers’ technical provisions, the Solvency II regulatory regime that will come into force at the end of 2012 and the new EU supervisory structure from 1 January next year all ensure that consumers are well protected. The CEA supports the EC objectives of ensuring a high level of consumer protection in the EU, but the new solvency and supervisory rules should be afforded sufficient time to be fully implemented and tested before any additional layers of protection are considered. 

The CEA also believes that the EC should recognise that consumer protection needs are different in the insurance sector to the banking sector. The type of problems that bank guarantee schemes address do not exist in the insurance sector, where winding-up procedures usually take years, liquidity management is less of an issue and there is less risk of contagion between entities.

Should the EC nevertheless decide to go ahead with a legislative initiative on IGS, the CEA believes that a minimum harmonisation of national schemes is the most appropriate way forward. This would accommodate the established national systems that are adapted to local conditions and consumer needs. National IGS should strictly follow the home member state principle to avoid duplication of or gaps in coverage. 

The CEA believes that any EU Directive should only require national IGS to cover life insurance policies, which typically involve larger amounts and longer-term commitments with insurers. The CEA also believes that IGS should only cover consumers, and not undertakings, and that decisions on funding arrangements should be left to member states, provided that equivalent protection is provided to policyholders.

The CEA also strongly opposes the idea of a mutual borrowing facility between national IGS on the grounds that the insurance sector, in contrast to banks, is exposed to only limited liquidity risk.




© CEA - Comité Européen des Assurances

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