EFAMA comments on the European Commission proposal for a Directive on insurance mediation

21 September 2012

The European Fund and Asset Management Association (EFAMA) fully supports the policy objectives the Commission seeks to achieve with the overall PRIPs initiative, and feels committed to make a constructive contribution to the legislative debate.

EFAMA supports the objective of the European Commission to align the regulation of the marketing and selling of all types of PRIPs to retail investors across the Union. EFAMA therefore welcomes the proposal to amend or enhance relevant provisions in the Insurance Mediation Directive (IMD) to ensure a consistent approach to the regulation of retail financial product distribution in the Union.

Additionally, EFAMA believes that in order to ensure comparability for retail investors, IMD PRIPs and MiFID PRIPs altogether should be seen as “the whole of the market”.

Key comments:

• 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.
• EFAMA therefore welcomes that the definition of an IMD PRIP is not stand-alone 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.

Full position

© EFAMA - European Fund and Asset Management Association