Insurance Europe recently outlined its views on the Key Information Document (KID) to be used for packaged retail and insurance-based investment products, highlighting the importance of appropriately setting out features of a product in the KID. One of the main takeaways is Insurance Europe’s view that the premium for an insurance-based investment product should be set out separately to the product’s investment cost. It believes combining the two figures prevents consumers from being able to meaningfully compare either the premiums or investment costs between different products. It also fears that an aggregate ‘costs’ figure may make products appear more expensive thereby deterring consumers from purchasing them at all.
Insurance Europe also reflects on the impact of the new Insurance Distribution Directive in relation to insurance-based investments products. It welcomes the introduction of an assessment of the appropriateness and suitability of these products as well as the new rules around product oversight and governance.
A link to the key messages document is here.