Insurance Europe has responded to a European Commission consultation on the financial conglomerate directive (FICOD).
Insurance Europe said that the purpose of FICOD should be to ensure there are no gaps between sectorial legislation, and to avoid duplication and overlap with sectorial regulation, including guidelines issued by the European Supervisory Authorities.
Insurance Europe warned that this is currently not being fully achieved, in part because FICOD was designed and written before Solvency II came into force. Therefore, FICOD should be updated to recognise Solvency II and avoid duplication of requirements already covered by Solvency II.
Insurance Europe also said that, due to a lack of clarity on definitions and scope and/or supervisory discretion, insurance groups can currently be required to apply Solvency II, the capital requirements directive and FICOD simultaneously. Insurance Europe said this leads to significant unnecessary expense and effort, and avoiding this should be a key aim of any future changes to FICOD.