On 29 October 2012, the European Parliament published a working document on the European Commission’s proposed Insurance Mediation Directive II (“IMD II”). This document raises a number of issues that the European Parliament believes need to be considered, including:

  • whether the appraisal of claims should be included within the scope of IMD II;
  • the fact that the European Commission’s proposal provides for a number of delegated acts, which would lead to maximum harmonisation in certain important areas;
  • the resources that will be allocated to EIOPA to enable it to perform the tasks conferred on it under those delegated acts;
  • whether insurance investment products are actually comparable with pure investment products and should therefore be subject to the same rules;
  • whether a fee-based system for the mediation of insurance investment products would actually translate into better advice to customers; and
  • the technical difficulties arising from the provisions on conflicts of interest and transparency.

The European Parliament is currently scheduled to consider IMD II at its plenary session on 20-23 May 2013.