Insurance Europe says the EU must ensure that the proposals for change to the Insurance Mediation Directive (IMD2) must be flexible and proportionate. Its key messages are:
- IMD2 should not extend to insurers or to non-mediation activities;
- conflicts and remuneration policies should be designed with customer interests in mind and be risk-based;
- consumers should have access to non-advised sales;
- regulators must take care not to over-regulate or duplicate (particularly bearing in mind insurance Packaged Retail Investment Products (PRIPs); and
- there must be a consistent approach to regulation across financial products in respect of cross-selling practices.