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On ICP 18, Insurance Europe said that the suggestion in the text to overlook the legal requirements of individual jurisdictions, and to apply a different standard, undermines the supervisor’s objectives in setting their jurisdictional requirements, potentially resulting in a loss of choice for policyholders, and a negative impact on insurance penetration.
On ICP 19, Insurance Europe highlighted the need to make the principle of proportionality more evident, especially in terms of the requirement for senior management to evaluate implementation and monitoring procedures. Such excessively detailed procedures — assessment, review and recording — would be too onerous to implement, particularly for small firms.
Full response - Intermediaries
Full response - Conduct of Business