EBF preliminary position on the European Commission proposal for an insurance mediation directive (Recast)

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1 EBF Ref.: D2142F Launched in 1960, the European Banking Federation is the voice of the European banking sector from the European Union and European Free Trade Association countries. The EBF represents the interests of some 4,500 banks, large and small, wholesale and retail, local and cross-border financial institutions. Together, these banks account for over 80% of the total assets and deposits and some 80% of all bank loans in the EU alone. EBF preliminary position on the European Commission proposal for an insurance mediation directive (Recast) Key points The European Banking Federation would like to stress that any new regulation should be consistent with the existing legislation such as Consumer Credit Directive 1 as well as with the ongoing revision of the Markets in Financial Instruments Directive 2 (MiFID 2). It should not create significant additional costs without the certainty that added value to the customer will be provided. The EBF believes that the requirement on the ban on tying may not be in the interest of the consumer as it will ultimately limit this practice as well as consumer choice quite significantly, with the requirement for the distributor to offer each of the different components of the insurance package separately. One of the main objectives of the directive is to provide better information to consumers. The EBF believes that the information on the amount of the remuneration being received by the intermediary is excessive. In general, customers are interested to know the exact insurance coverage acquired and its real scope. The EBF considers that the definition of advice is too broad. Advice should mean the provision of a recommendation, tailored to a single customer for one or more specific products, which represents a separate activity from the mediation of insurance products. With this in mind, the definition of advice should be adapted and aligned with the definition provided in MiFID 2 and the Directive on Credit Agreements Relating to Residential Property 3 (CARRP). The EBF is also critical as regards the proposed differentiation between advice provided on an independent or a non-independent basis (Article 24.3). 1 Directive 2008/48/EC of the European Parliament and of the Council of 23 April 2008 on credit agreements for consumers and repealing Council Directive 87/102/EEC, OJ , L 133/66 2 Directive of the European Parliament and of the Council on markets in financial instruments repealing Directive 2004/39/EC of the European Parliament and of the Council (Recast) COM(2011) 656 final 2011/0298 (COD) 3 Proposal for a directive of the European Parliament and of the Council on credit agreements relating to residential property COM(2011) 142 final - COD 2011/0062 EBF a.i.s.b.l ETI Registration number: Avenue des arts 56 Brussels +32 (0) Phone +32 (0) Fax

2 The European Banking Federation (EBF) takes note of the publication of the European Commission s proposal for a Directive on insurance mediation (recast) which aims to improve regulation in the retail insurance market. The EBF welcomes the initiative of the European Commission to create a level playing field with undistorted competition in the insurance mediation sector within the European internal market. Nevertheless, the EBF would like to stress that when creating an integrated market, it is necessary to take into account the peculiarities of the sales structures that exist in individual Member States. In addition, the EBF believes it is important to ensure a high level of protection for all consumers purchasing insurance products. Nonetheless, some points of the proposal should be adjusted and adapted to the current market reality. A. The scope The EBF shares the view of Mr. Werner Langen, Rapporteur for the European Parliament Economic and Monetary Affairs (ECON) Committee, in his working document 4, that it is questionable to include professional management of claims and loss adjusting, in the scope of the directive. The EBF agrees that, from the point of policyholder protection, there would be no direct interest in such an extension. Moreover, the European Insurance and Occupational Pensions Authority (EIOPA) had advised against the inclusion of this activity in IMD2. B. Professional and organizational requirements Article 8 Considering that professional and training requirements are essential elements to guarantee consumer protection in the framework of the insurance mediation, the EBF believes that it should not be possible to introduce delegated acts in this area. C. Out-of-court redress Article 13 Article 13 of the proposal provides that Member States shall ensure the setting-up of appropriate, effective, impartial and independent complaints and redress procedures for the outof-court settlement of disputes between insurance intermediaries and customers, and between insurance undertakings and customers, using existing bodies where appropriate [ ] In order to ensure legal certainty and to avoid inconsistencies, the EBF believes that, rather than setting up new procedures, the out-of-court settlement of disputes between insurance intermediaries and customers should comply with the existing Alternative Disputes Resolution (ADR) or, with the ADR directive and Online Dispute Resolution Regulation which will soon be adopted. 4 ECON Working document on insurance mediation directive 16 October

3 D. Conflicts of interest and transparency Article 17 On the obligation to disclose information on the amount of the remuneration Article 17.1 One of the main objectives of the directive is to provide better information to consumers. The EBF believes that the obligation to provide information on the amount of the remuneration being received by the intermediary is excessive. In general, customers are interested to know the exact insurance coverage acquired and its scope. The obligation to provide information on the remuneration (article 17.1) received by the intermediary does not offer further customer protection since the client will be interested in the total price of the insurance product, so as to compare it with other products, rather than the cost elements. The EBF also believes that excessive disclosure could be confusing and misleading for consumers who will not focus on the important policy information such as coverage, exclusions etc. Eventually, a minimum of information on remuneration could be established. For example, its nature (commission, fixed rate, etc.), origin (insurance company, intermediary, client) etc., without stating the exact amount that might even contradict competition rules. Be that as it may, owing to the complexity of this information it should provided only if specifically requested by the client, and not as a mandatory obligation. In addition to improving transparency, standards on how the information should be disclosed could be considered. On the transitional period for the disclosure of obligations - Article 17.2 At the same time, it is worth noting that, given the wording, the provision under Article 17.2 concerning the transitional period for the disclosure obligations for non-life insurance products is equivalent to an expanded disclosure requirement that would come into effect even before the end of the transitional period. This, despite the fact that under the current proposal, an intermediary mediating non-life insurance policy is only required to disclose the basis of calculation of its remuneration to the client at the pre-contractual stage, when requested by the client. The insurance intermediary is obliged to inform the client of his/her right to request such information. In order to ensure a genuine transitional period, the EBF suggests deleting Article 17.2 (b). On the obligation to inform a client about the basis of the calculation of possible variable remuneration received by an employee - Article 17.3 In the EBF s opinion, the obligation to inform a client about the basis of the calculation of possible variable remuneration received by an employee (Article 17.3), is excessive and does not provide any additional consumer protection. This provision is not consistent at all with the ongoing revision of MiFID 2 which does not include the obligation to disclose to the customer the variable remuneration of the employees. According to the MiFID 2 approach, the staff remuneration policies should be part of the general policy of the insurance intermediary or insurance undertakings related to conflict of interests. 3

4 Consistent with the objectives of the recast of the Directive on insurance mediation, the alignment of the proposal, on transparency of remunerations, with the proposed MiFID 2, is requested. According to this provision, insurance undertakings or insurance intermediaries and thus also banks acting as insurance intermediaries should disclose the nature and basis of the calculation of any variable remuneration received by their sales staff. The recitals of the draft proposal justify this measure, given that it should prevent conflicts of interests. In the EBF s opinion, it is doubtful whether disclosure of the variable remuneration of individual staff members will be of any benefit, at all, in terms of the underlying objective. Especially, given that, on conclusion of a contract, compliance with this requirement will be almost impossible. The EBF would therefore suggest deleting this section. In addition, it is important to stress that this does not mean that the information is not available to the national supervisory authorities. Similar comments may be applicable to payments that are made by the customer under the insurance contract and in the case of the customer paying an additional fee according to the contract. On the delegated acts As regards the European Commission s power to adopt delegated acts on the disclosure of information, the EBF considers that it could lead to business uncertainty. Indeed, remuneration is usually submitted to the freedom of contract and is part of the negotiation between the parties involved in the contract. E. Cross-selling Article 2.19, 2.20 and article 21 It is usual, especially among insurance intermediaries such as banks, to offer an insurance service or product together with another financial service or product as a package. This practice is common, chiefly, in the banking sector where credit institutions frequently act as insurance intermediaries: i.e. bundle credit cards with travel insurance. The EBF considers that the ban of cross-selling, and hence the definitions on tying and bundling practices, leave room for various interpretations. The EBF is convinced that consumers should still be able to obtain products which allow them to insure themselves and their surviving relatives, against the risk of death during the contractual term of a loan, or during the capital accumulation stage of a savings plan or pension scheme, for example. Clarification would also be appropriate with regard to the residual debt insurance which protects borrowers or their dependents against social hardship in the event of illness, unemployment or death. The bottom line is that this equally applies to supplementary occupational disability insurance, and supplementary fatal accident insurance, in combination with life insurance. If such tied products were declared illegal, this would ultimately be to the detriment of policyholders or of the wider community [i.e. social security systems] in critical situations. 4

5 Another example is a life insurance bought in order to secure a credit. However, in this case the life insurance is not an incentive to persuade the customer to conclude the contract but is bought to reduce the risks of the creditor, so it is often an unconditional condition to get the credit. More clarifications on definitions needed The EBF suggests clarification on the definitions. The definition on tying should refer to Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market that already deals with tying practices. The selling or offering for sale of bundled products or services should not be qualified as a tying practice and prohibited as such if the products or services included in the bundled offer cannot be separated (e.g. payment instruments insurance sold with a bank card or credit card). One option would be adding the following wording to recital (19): (19) tying practice means the offer of one or more ancillary services with an insurance service, or product in a package, when this insurance service or product is not made available to the consumer separately. Tying practice does not refer to the optional offer of one or more insurance products as a supplement to a financial service. The ban on tying considered as too excessive The EBF considers that bundling practices offer a broad choice and a good protection for consumers. As such, the EBF believes that the requirement under Article 21.2 on the ban on tying is excessive as it limits these practices considerably, with the requirement for the distributor to offer each of the different components of the insurance package separately. The EBF notes the examples set out in Recital 41 and agrees that these types of practices should not be permitted. However, it believes that the outright ban on tying will be harmful to consumers. In particular, it will result in banks ceasing to provide insurance products that are currently provided free of charge to consumers, e.g. travel insurance with a credit card. The EBF proposes, therefore, that some limited exceptions for the ban on tying should be provided when it is justified and in the interest of the consumer. Pursuant to this proposal, information would have to be provided separately on the costs and charges of each component of a package of insurance services or products. Instead of exposing customers to a real flood of information ( forcing this benefit on them ), transparency should be enhanced. To this end, the customer should be informed of whether a package is involved, and only receive further information when this is specifically requested. In the EBF s view, this approach serves clients interests more effectively. In the final analysis, detailed breakdowns of costs and charges, in which clients themselves are not interested, only lead to a situation where the advice is artificially inflated, thus causing clients to lose sight of what really matters. Clients run the risk of information overload. Therefore, the EBF proposes the following amendment to Article 21.2: 5

6 2. When an insurance service or product is offered together with another service or product as a package, the insurance undertaking or, where applicable, the insurance intermediary shall offer and inform the client whether it is possible to buy the components of the package separately. and At the client s request, the insurance undertaking, or where applicable, the insurance intermediary, shall provide information of the costs and charges of each component of the package that may be bought through or from it, separately. The importance of ensuring consistency with existing legislations and the forthcoming MiFID2 The EBF would also like to stress the importance of the IMD2 Directive being consistent with the existing legislation such as the Consumer Credit Directive 5, the ongoing discussions on the Directive on Credit Agreements Relating to Residential Property (CARRP), and the review of MiFID 2. For example, in the proposed cross-selling practices provision in MiFID 2, where there is only an obligation to inform the customer whether it is possible to buy the different components separately. As a result, the IMD 2 proposal goes much further than the MiFID 2 provision, without any justification. EIOPA power to develop guidelines: the control by national competent authorities should remain Furthermore, the EBF would like to raise some concerns regarding the European Insurance and Occupational Pensions Authority s (EIOPA) power to develop guidelines for the assessment and supervision of cross-selling practices. Indeed, the EBF believes that this control should be kept by the national competent authorities. Hence, the EBF deems it not appropriate to introduce a ban on these concepts without a thorough analysis of what is meant by tying and bundling within different product areas and what effects these practices might have on consumers. F. Advice Definition of advice Article 2.9 The EBF considers that the provision of advice is essential for consumer protection, as it allows the consumers to receive the information they need, in order to make informed decisions. The EBF would like to stress that providing advice should be considered as a service that is distinct from the provision of information and explanations on the products. Accordingly, full harmonisation of the proposal s provisions related to advice is requested in order to leave no room for diverging rules at national level, and to ensure consumer protection within the internal market. In this perspective, the EBF is of the opinion that the definition is too broad. 5 Directive 2008/48/EC of the European Parliament and of the Council of 23 April 2008 on credit agreements for consumers and repealing Council Directive 87/102/EEC, OJ , L 133/66 6

7 Advice should mean the provision of a recommendation, tailored to a single customer for one or more specific products, which represents a separate activity from the mediation of insurance products. With this in mind, the definition provided by article 2.9 should be adapted and aligned with the definition provided in MiFID 2 and the Directive on Credit Agreements Relating to Residential Property 6 (CARRP). In particular, the word personal should be included after the word recommendation in the definition of advice in Article 2(9). This would be consistent with the Explanatory Memorandum. In addition, it needs to be clarified whether sales, without providing advice, is possible according to this directive (execution only). This would be of relevance when it comes to online sales. The EBF is of the view that consumers should be able to purchase any insurance product without advice. Indeed, in some cases, the consumers who do not need/want advice consider that providing advice could interfere with their consumer choice. And, in the case of consumers unable to afford such advice, its imposition could be an obstacle to accessing products. General principles and information to customers Article 24 The EBF is critical as regards the proposed differentiation between advice provided on an independent or a non-independent basis (Article 24.3). Pursuant to Article 24.1 all insurance intermediaries and insurance undertakings have to act in accordance with the best interests of their customers. The fact that conflicts of interest may arise applies to any intermediary and insurance undertaking, i.e. it is also true in the case of fee-based advisory services. Hence, the IMD2 should not give rise to a preferential treatment for fee-based advisory services, thus discriminating against those forms of insurance mediation which have established themselves in the market and which ensure that citizens can benefit from insurance coverage. The information obligation laid down under Article 24.3 (a) is identical to the general requirements under Article 16 (a) (i), (ii) and (v) as well as in Article 17.1 c, therefore the EBF suggests deleting it or at least replacing on-going assessment by periodical assessment, in line with the European Parliament Economic and Monetary Committee report on MiFID 2 7. In EBF s view an on-going assessment can only relate to providing the customer with the latest information concerning his/her insurance product when it comes to life insurance products which are invested in funds. An on-going, i.e. repeated assessment of the suitability of an insurance product for the client is virtually impossible. This always depends on the client requesting (further) advice or information. In this light, the EBF believes that any compulsory advice going beyond should not be considered and a periodical assessment should be preferred, in line with the ECON report on the MiFID 2. 6 Proposal for a directive of the European Parliament and of the Council on credit agreements relating to residential property COM(2011) 142 final - COD 2011/ ECON report on the proposal for a directive of the European Parliament and of the Council on markets in financial instruments repealing Directive 2004/39/EC of the European Parliament and of the Council (recast) (MiFID 2) 5 October

8 G. Sanctions and Measures The general principles underlying the proposed sanctions regime: administrative sanctions should be effective, proportionate and dissuasive. The Commission s proposed clarification of the factors that must be taken into account when determining sanctions, such as the gravity and duration of the breach or the level of cooperation with the competent authority, should be supported. However, the current proposal raises various concerns as regards the subsidiarity and proportionality principles. It appears that the new sanction regime does not meet the requirements of two essential principles of the EU Treaty, namely, subsidiarity and proportionality (Art. 5.3 of TFEU). Indeed, according to the subsidiarity principle, the power for the EU to define the level of administrative pecuniary sanctions is not justified. Subsidiarity falls under the competence of the Member States national courts. Furthermore the EBF considers that it is important to question the fact that the administrative authorities have the right to determine severe penalties on natural persons without preconditions for individual responsibility being specified. As regards the principle of proportionality, the European Court of Justice has consistently held that the acts adopted by EU institutions must not exceed the limits of what is appropriate and necessary in order to attain the legitimate objectives pursued by the legislation in question. The proposal to impose an administrative pecuniary sanction of up to 10% of the total turnover of the legal person in the preceding business year seems totally disproportionate, and exceeds what is appropriate and necessary in order to reach the objectives. In any event, it is essential to ensure consistency across the different EU initiatives touching upon administrative sanctions, so as to achieve legal certainty. In addition, the EBF would like to draw attention to article 28 (2) (d) under which members of the management body responsible for a violation may be subject to a ban to exercise functions in insurance intermediaries and undertakings. In the proposal, no time limit is inserted which means that this could become a perpetual disqualification. If such a ban is introduced, there must be a time limit and guarantees for access to legal rights. Against this background, the EBF considers that the provision in article 26 (2), and the following articles on sanctions against natural persons must be deleted. Publication of sanctions Article 27 The publication of sanctions would contribute towards increased transparency, as market operators would be made aware that a breach has been committed by a particular person. As a result, actual and potential perpetrators would be deterred from committing offences, not lease to avoid significant reputational damage. 8

9 However, in line with the European Data Protection Supervisor s position on MiFID 2 8, the EBF is of the view that the provision on the mandatory publication of sanctions as it is currently formulated does not comply with the fundamental right to privacy and data protection law as clarified by the Court of Justice in the Schecke judgment 9 The EBF believes that the need to publish sanctions should be assessed. It should be checked whether the publication obligation goes beyond what is necessary to achieve the public interest objective pursued, and whether there are not fewer restrictive measures to attain the same objective. Subject to the outcome of this proportionality test, the EBF considers that the publication obligation should be supported by adequate safeguards to ensure respect of the presumption of innocence, the right of the persons concerned to object, the security and accuracy of the data, and their deletion after an adequate period of time. The EBF is against the proposed publication of sanctions, including disclosure of the identity of the persons responsible (Article 27). It is important to stress that an ex ante assessment of whether such a publication will cause disproportionate damage to the parties involved, will be difficult execute. This is because the impact of publication depends to a great extent on several changing external factors. Furthermore, the proposed rule is in breach of the rule-oflaw principles because it effectively leads to double sanctions against the sanctioned persons. These persons would be the target of the sanction (for instance, by having to pay a fine) and face the publication of the sanction. The EBF therefore suggests deleting article 27. H. Transposition Article 36 The EBF draws attention to the time and resources required for business operators to adapt their processes being greatly under-estimated by the European regulator. As a result, the transposition period is often too short. The EBF argues in favour of a specific time period leaving sufficient time for the companies to implement the text after the date of the entry into force of the implementing legislative text at national level. * * * Contact Person: Sébastien de Brouwer Noémie Papp Related documents: European Commission proposal for an insurance mediation directive (Recast) 8 Opinion of the European Data Protection Supervisor on the Commission proposals for a Directive of the European Parliament and of the Council on markets in financial instruments repealing Directive 2004/39/EC of the European Parliament and of the Council, and for a Regulation of the European Parliament and of the Council on markets in financial instruments and amending Regulation on OTC derivatives, central counterparties and trade repositories OJEU C 147/1 9 Joined Cases C-92/09 and C-93/09, Schecke, paragraphs

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