On 19 September 2013, the European Insurance and Occupational Pensions Authority (EIOPA) published a letter from its chairman, Gabriel Bernardino, to the European Commission, expressing his concerns about the sale of insurance investment products being brought within the scope of MiFID II. Mr Bernardino is concerned that such inclusion will result in; 

  1. a potential lack of regulatory consistency and  
  2. a detrimental impact on consumer protection.

He believes that a possible solution is for the current MiFID II process to include some simple amendments to IMD1, thereby ensuring that the sale of insurance-based investments remains within the regulatory scope of insurance mediation.