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In its response, Insurance Europe pointed out that the proposed guidelines could lead to too many prescriptive and overly-formal POG processes. This would significantly increase insurers’ administrative workload and detrimentally affect insurers’ competitiveness.
Insurance Europe warned that any additional administrative costs would ultimately have to be borne by policyholders. Therefore, the focus of any proposed POG provisions should be on more demanding, sophisticated insurance products.
Insurance Europe also expressed concern that EIOPA is pre-empting the political discussions regarding POG that will take place during the trialogues on IMD2 with such guidelines.