- IDD - no ban on commissions, one of the most important features of the directive; decision is left to the national authorities;
- IDD also provides for the IPID introduction - potential beneficial for customers, but difficult enough for the industry;
- IPID should not be only workable for the industry, but also understandable for consumers; also it needs to be fully compatible with digitalization;
- A very important aspects includes the level 3 processes, which assure the coherent implementation of the EU legislation across the EU member states - is important that EIOPA, while elaborating the guidelines, does not affect the full control of the national authorities on the issues that the Level 1 legislation has left to their latitude;
- Customer protection rules that EIOPA is currently elaborating may affect every single aspect of the insurers' activity - for example, Level 3 guidelines on data protection will affect customer profiling, i.e. the underwriting process, so implications are of very large scale, requiring a very careful consideration.
- Due to provisions under different pieces of new regulations, life insurance consumer might receive a double volume of information - too much, too complex, ineffective from the consumer point of view and very expensive for insurers. There is a strong need to pay attention to the cumulative impact of the EU legislation!
- PRIIP's regulation application officially delayed 1 year (first deadline - Jan 1st 2017);
- IDD - Level 2 provisions will not available before October 2017.
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