CEA has responded on the Commission consultation on PRIPs. It stresses the complexity of many insurance products and how difficult it will be to assess whether a particular life insurance product should be a PRIP and says a one-size-fits-all approach cannot work. On the other hand, it highlights that some deposit products can directly compete with insurance products and should be regulated consistently. It thinks at this stage the initiative should exclude pensions and annuities. On disclosure, it thinks the KIID should be outcomes-based, rather than based on length or similar criteria, that it should be flexible to reflect the differences in products, and that it should be possible to adapt a KIID to local consumer needs. It agrees it is important to have a clear division of responsibilities between provider and distributor but says it should be possible for the two to agree the distributor may draft the KIID. Finally, it says that products should only be permitted to describe a “guarantee” where they are supported by appropriate obligations and capital requirements. (Source: CEA response to the European Commission’s consultation on legislative steps for the Packaged Retail Investment Products (PRIPs) initiative)