Insurance Europe has responded to the International Association of Insurance Supervisors’ (IAIS) consultation on its draft Issues Paper on customers receiving value from insurance products.
Insurance Europe welcomes the IAIS’ recognition of the essential role insurance plays in protecting individuals and businesses, supporting societal resilience and contributing to economic stability. It also supports the IAIS’ acknowledgement that supervisory approaches should reflect differences between jurisdictions, products and market conditions.
In Europe, the design and distribution of insurance products are already subject to a robust consumer protection framework. This includes the Insurance Distribution Directive (IDD), Product Oversight and Governance (POG) rules, EIOPA’s supervisory work on value for money and the new requirements being introduced under the Retail Investment Strategy (RIS). The existing framework is already enabling national competent authorities to have adequate powers and supervisory tools to intervene where necessary.
In its response, Insurance Europe recommends any supervisory approach to:
To help ensure a balanced tone in the IAIS’ final Issues Paper, Insurance Europe also recommends clarifying several points. These include recognising the benefits that cross-selling can bring, acknowledging a broader range of factors that can enhance the value offered by insurance products, and avoiding any suggestion that the payment of commissions is inherently problematic, as it represents legitimate remuneration for the service provided by insurance distributors.