The European Insurance and Occupational Pensions Authority (EIOPA) is carrying out an on-line survey, in anticipation of a “Call for Advice from the European Commission on the delegated acts under the Insurance Distribution Directive”.

The Insurance Distribution Directive (IDD) gives the Commission the power to adopt delegated acts on (a) Product Oversight and Governance Arrangements; (b) the Management of Conflicts of Interest; (c) Inducements; and (d) the Assessment of Suitability and Appropriateness, and Reporting to Customers. The delegated acts could have a material impact on business models and market structures. So EIOPA wants to hear from market participant before it prepares its draft technical advice to the Commission in due course.

The survey, which closes at 11pm (CET) on 22 January 2016, includes 21 sets of questions. For example:

  1. … under which circumstances should the activities of an entity (in particular of an intermediaries [sic]) be considered as manufacturing of [sic] insurance products?
  2. … Would you consider it appropriate and necessary requiring [sic] manufacturers to ensure that the insurance products are fairly priced and offer added value to customers?
  3. According to Article 29(2), … monetary and non-monetary benefits which are provided in connection with the distribution of an insurance-based investment product or an ancillary service should not have a “detrimental impact” on the quality of the relevant service to the customer … which criteria and methodology should be applied to assess whether a benefit has a detrimental impact on the quality of the service?
  4. Apart from the insurance contract (Article 30(3), IDD), the suitability statement (Article 30(4), IDD) and the periodic reports (Article 30(4), IDD), what information should the distributor be required to record?” and
  5. At what frequency should periodic reports (Article 30(4), IDD) be provided to the customers and what information at a minimum should be contained in the reports?”

There’s more information about the survey, and the latest thinking on the timing of the IDD, here. The near-final version of the IDD is available here.