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03 July 2012

Eurofinas: EC proposal for the IMD II - Avoiding a one-size-fits-all approach is key


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Eurofinas regrets that the Commission has opted for a minimum harmonisation approach. Indeed, allowing Member States to adopt more stringent measures (gold-plating) will generate regulatory inconsistencies and gaps across the EU which is contrary to the original objective of IMD II.


Eurofinas nonetheless considers the proposal to be a good starting point. In particular, Eurofinas commends the European Commission for proposing a regulatory framework that takes into account the differences between the various distribution channels as well as the complexity and nature of the various products distributed, thereby avoiding the pitfall of an ill-suited one-size-fits-all approach.

“A one-size-fits-all approach would have been based on the false assumption that all insurance intermediaries are in the same business, create the same risks and therefore should be subject to the same rules. This is inherently incorrect”, said Eurofinas’ Director General, Tanguy van de Werve.

Differentiated rules allow for regulation that balances the administrative burden placed on intermediaries and permits professional requirements to be tailored to the type of intermediaries and to the complexity of the products being mediated. This proportional treatment is especially important for those intermediaries who distribute insurance products ancillary to their principal professional activity, such as retailers and motor dealers.

“Hence we call on the Members of the European Parliament and on the Council to maintain this differentiated approach and ensure that the requirements of the new Directive are adapted to the different channels”, added van de Werve.

Press release



© Eurofinas


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