Insurance Europe has published its response to a consultation by the European Commission on the Directive on the Distance Marketing of Consumer Financial Services (DMD).
Insurance Europe highlighted concerns about the continued relevance of the DMD in the light of more recent product specific legislation, such as the Insurance Distribution Directive (IDD). It also noted changes in consumer expectations that are linked to technological advances and uses.
The DMD should be reviewed to ensure that only relevant provisions are retained, and ideally supplanted into product specific legislation. In any event, in the case of any inconsistences between the DMD and product specific legislation, such as the IDD, the latter should take precedence in the interest of legal certainty.