While welcoming the project’s aims to increase the share of the population with private pensions and the allocation of funds to long-term investments, Insurance Europe said that to be suitable as a source of retirement income, the PEPP must truly be a long-term product.
Consumers should be incentivised to save for a long period, ideally until retirement, for instance through minimum investment periods. This would in turn allow PEPP providers, such as insurers, to access the benefits of being able to invest long-term.
The PEPP should offer policyholders an appropriate level of security. This includes protection against longevity risk and — taking account of national practices in the member state concerned — access to guarantees or additional coverage against biometric risks, such as disability.
Insurance Europe has developed a key information checklist for PEPP pre-contractual information requirements that would be tailored to the specific nature of the PEPP. In this regard, it should be noted that the Packaged Retail Investment and Insurance Products (PRIIPs) Regulation would not be the right benchmark and would mislead pension savers.
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