Response from the Danish FSA regarding the consultation on the Review of the Insurance Mediation Directive (IMD)

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1 European Commission DG Internal Market and Services B Brussels 2 March 2011 Response from the Danish FSA regarding the consultation on the Review of the Insurance Mediation Directive (IMD) The Danish FSA welcomes the initiative by the European Commission to conduct a review of the Insurance Mediation Directive (IMD) and finds that the member states should continuously aim to guarantee a high level of consumer protection as well as a high level of professionalism and competence among insurance intermediaries. DANISH FINANCIAL SUPERVISORY AUTHORITY Aarhusgade Copenhagen Denmark Tel Fax MINISTRY OF ECONOMIC AND BUSINESS AFFAIRS The Danish FSA fully supports the intention of the European Commission to ensure a level playing field to the benefit of consumers by including direct sales in the IMD and taking into account the initiative put forward by the Commission on Packaged Retail Investment Products (PRIPs) regarding sales practices. Below you will find the Danish perspective on the most important in the consultation document on the Review of the IMD focused on the following areas: 1. Prohibition on receiving commissions for brokers 2. A high and consistent level of policy holder protection in EU law 3. Effective management of conflicts of interest and transparency 4. Introducing clearer provisions on the scope of the IMD 5. Increasing the efficiency in cross-border business 6. Achieving a higher level of professional requirements 1. The Danish prohibition on receiving commissions for brokers As mentioned in the CEIOPS report to the Commission regarding conflicts of interest, remuneration can influence the intermediary, when he/she has to

2 2 explore the market on behalf of a client 1. In the interest of general good, the Danish Act on Insurance Mediation therefore contains a prohibition on receiving commission or other remuneration from insurance companies when pursuing activity as an insurance broker in Denmark. The prohibition has been in place since It is the view of the Danish FSA that the experiences in connection to the prohibition are very positive. This applies both to the reduction of conflicts of interest and the enhancement of transparency of remuneration. In addition it is our view that a removal of the prohibition will be detrimental to consumers. The Danish FSA therefore recommends the Commission to keep the IMD as a minimum harmonization directive with the possibility for Member States to introduce stricter national requirements. The Danish prohibition on receiving commission or other remuneration from insurance companies only applies to brokers. In Denmark, insurance brokers are obliged to provide an objective advice to his or her costumers. In that sense insurance brokers are bound to be absolutely independent of any insurance company 2. Insurance agents are not covered by the prohibition 3. This is due to the fact that in Denmark insurance agents are not considered as independent of the insurance companies, since agents sell insurance products of insurance companies according to an agreement with one or more insurance companies. Consequently the customer does not expect objective advice from an insurance agent. This is the reason why it has not been estimated as necessary to prohibit the insurance agents from being paid by the insurance company. However, insurance agents have an obligation to inform the customer that they are tied agents and are paid by the insurance undertaking. In addition agents will also have to disclose the remuneration that they have received upon request from the customer. 1 CEIOPS: CEIOPS Advice to the European Commission on the revision of the Insurance Mediation Directive (2002/92/EC), p In the Danish Act on Insurance Mediation brokers are defined as intermediaries performing an activity consisting of providing the customer with advice on the basis of an analysis of as many as possible of the insurance solutions available on the market; and an activity consisting of presenting to the costumer insurance solutions from one or several insurance companies without an explicit agreement to this effect having been entered into with the said insurance companies. 3 In the Danish Act on Insurance Mediation insurance agent activities are defined as the activity consisting of selling the insurance products of an insurance company according to an agreement with one or more insurance companies.

3 3 A similar argument can be made with regard to direct sales, if this is included in the IMD. It is our view that the prohibition on receiving commissions for insurance brokers has led to a reduction of conflicts of interest. The introduction of the ban has made sure that the choices of the brokers only depend on the preferences of the customers and not on the commission rates that the insurance undertakings offer to the broker. In addition it is also our view that the prohibition on receiving commissions has lead to enhanced clarity in the charging structures of brokers, since the customers pay the brokers directly for the service that the brokers perform. It creates clearer communication to the consumers and it also results in a clear link between the performance by the broker and the payment structure. The Danish industry of insurance brokers and insurance undertakings both highlight, that they are very satisfied with the existing system. And it is our view that the prohibition enhances transparency and competition between both insurance undertakings and insurance brokers. While the brokers have increased their competition on the price of the brokerage service, the prohibition has also put pressure on the insurance undertakings and the prices that they are able to offer on the individual policies. The prohibition in a cross-border context When an EU based insurance broker notifies the Danish Financial Supervisory Authority about his wish to pursue insurance broker activity in Denmark the insurance broker is informed about the conditions under which to perform insurance broker activity in Denmark and about the prohibition on receiving commission from the insurance companies. As previously mentioned insurance brokers pursuing activity in Denmark are not allowed to receive commission from Danish insurance companies or from insurance companies established through a branch in Denmark. In order to ensure that a customer can receive insurance cover by a foreign insurance company which is not domiciled or established by a branch in Denmark the broker is - as an exception to the general prohibition - allowed to receive commission from insurance companies pursuing cross-border activities in Denmark. However, the insurance broker is obliged to forward the commission received to the customer. The prohibition does not apply to insurance brokers providing their service cross-border. A broker, who provides his/her services cross-border, is therefore still allowed to receive commissions from insurance companies.

4 4 The Danish FSA believes that the model concerning a prohibition on commissions is not an obstacle to the free provision of services. In that connection it is important to emphasize that we have not experienced any problems in connection to the reduction of cross-border activities as a result of the prohibition and that the size of the market seems unaffected by the prohibition. Conclusion regarding the Danish prohibition Based on the comments above the Danish FSA would urge the Commission to keep the IMD as a minimum harmonization directive with the possibility for Member States to introduce stricter national requirements such as the prohibition on receiving commissions for brokers in order to ensure an effective consumer protection. The Danish FSA could also accept a general prohibition on commissions in Europe with regard to insurance brokers. However, the Danish FSA acknowledges that this will not be obtainable due to the differences of the European markets of insurance mediation. Therefore the Danish FSA urges the Commission to keep the IMD as a minimum harmonisation directive, in order to allow member states to have stricter rules to the benefit of the consumer. 2. A high and consistent level of policy holder protection in EU law It is the view of the Danish FSA that the review of the IMD represents an ideal opportunity to raise the common European standards of consumer protection in connection to insurance distribution to a higher level than today. The Danish FSA supports that the review of the IMD takes into account the initiative put forward by the Commission on Packaged Retail Investment Products (PRIPs) regarding sales practices. It is important to ensure a coherent approach to the regulation of product disclosure and sales practices in order to avoid a grey area between MiFID and IMD with regards to PRIPs. In addition it is also important to keep in mind, that there are significant differences between investment and insurance, which should be reflected in the coming legislation. Exemptions (A2) The Danish FSA is of the opinion that the exemption in article 12(4) should be maintained for insurance intermediaries. From a Danish point of view the exemption covers customers that are usually sophisticated in terms of knowledge and financial capability and who normally receive information and advice tailored to their needs. The degree of information asymmetry is therefore considered to be minimal.

5 5 Minimum harmonisation (A3) Due to the differences between the markets in Europe, the Danish FSA recommends that the IMD is maintained as a minimum harmonization directive with a possibility for Member States to introduce stricter national requirements adapted to national market conditions. Definition of advice (A4 A5) The Danish FSA acknowledges that there is a need for more legal certainty in the IMD. The Danish FSA therefore supports the inclusion of a definition of advice in the IMD similar to the definition of advice in MiFID. This would also ensure a certain degree of consistency between the IMD and MiFID even though market specificities should be taken into account when defining advice in the IMD. In addition, it could be useful to add a definition of independent and dependent intermediaries in order to ensure a certain degree of clarity concerning the different types of intermediaries in the European market of insurance intermediation. Sale of insurance products without advice (A6) From a Danish point of view it should be possible to sell some types of insurances without advice. This could be the case for standardised types of insurances and/or compulsory insurance as e.g. travel insurance or household insurance. In addition, it should be possible for the intermediary or insurance undertaking to sell insurances without advice when a customer demand a certain specified product or if the product is relatively simple. It should be noted that the types of insurances which are compulsory or standardised vary between Member States. The Danish FSA therefore recommends that IMD2 should cover a number of general conditions to be met in order to be able to sell an insurance product without advice. In addition Member States should be allowed to introduce more detailed requirements to reflect national market conditions. The Danish FSA would recommend the Commission to consider introducing an instrument such as the appropriateness test, which applies in MiFID, when a customer wishes to buy a complex product without advice. The appropriateness test could be useful in connection to non-standardised products which could be sold without advice. This could help to ensure that the customer has the necessary understanding of the product before the acquisition of the product.

6 6 3. Effective management of conflicts of interest and transparency (B) The Danish FSA finds it essential that the review of the IMD leads to a focus on transparency and conflicts of interest. From a Danish point of view the current requirements in the IMD are not sufficient to prevent conflicts of interest and ensure transparency of remuneration. High level principles (B1-B4) The Danish FSA finds that any new requirements regarding conflicts of interest and transparency should apply to all distributors of insurance - that is both insurance intermediaries and insurance undertaking in order to ensure that all distributors have an obligation to avoid conflicts of interest and to manage any conflict of interest if it cannot be avoided. The Danish FSA supports that MiFID Level 1 requirements serve as a starting point for the management of conflicts of interest. However, it should be noted, that the requirements in MiFID will have to be adjusted to fit into the IMD e.g. because of the existence of one-man businesses in the market of insurance mediation. As mentioned above, it is our view that there are important differences in the service that is offered by agents and brokers. While Danish brokers are obliged to be independent of any insurance undertaking, agents act on behalf of one or more insurance undertakings when offering their services to their customers. Subject to the different kinds of intermediaries different types of conflict of interest arise, and therefore different measures seem appropriate to identify, manage and disclose these conflicts of interest to the customer. Transparency of remuneration (B4-B7) The differences concerning independent and dependent intermediaries are also essential with regard to transparency of remuneration. Therefore, the Danish FSA recommends that in connection to independent intermediaries a mandatory disclosure regime is introduced as a minimum requirement. This should be done in order to ensure, that the intermediary always presents the customer with information on the remuneration that the intermediary receives, irrespective of the type of product or market, and irrespective of the kind of remuneration that the intermediary receives. This implies that all customers will receive information on any remuneration that an independent intermediary receives. Regarding dependent intermediaries the Danish FSA recommends that an on request regime is introduced as a minimum requirement, stating that

7 7 dependent intermediaries will have to disclose the remuneration that they have received upon request from the customer. As mentioned above a prohibition on receiving commission or other remuneration from insurance companies when pursuing activity as an insurance broker has been in place in Denmark since The experiences with the prohibition are positive both with regards to conflicts of interest and transparency. From a Danish point of view we would therefore prefer to maintain an IMD framework that allows for the current prohibition. 4. Introducing clearer provisions on the scope of the IMD (C) The Danish FSA acknowledges that there is a need for more legal certainty in the IMD e.g. with regards to article 1(2) regulating exemptions from the IMD s scope. We support that the current activity based definition of insurance mediation is kept in the IMD, and we recommend that the current definition is supplemented with a definition of independent and dependent intermediaries. We also support that direct sales are covered by the IMD in order to ensure a level playing field to the benefit of consumers. For both intermediaries and insurance undertakings it is important to ensure that there is proportionality in the requirements set out in the future IMD. While some requirements are relevant for independent intermediaries other requirements are relevant for tied agents and insurance undertakings. It is important that this is kept in mind when drafting the future requirements. The Danish FSA supports that an insurance undertaking is conceived as an intermediary (an agent) if the insurance undertaking sells the products of another insurance undertaking. However it is important to notice, that this must not entail a reduction in consumer protection. With regard to the exemptions in article 1(2) of the IMD, these exemptions have been implemented verbatim in Denmark. In addition, we interpret the exceptions narrowly, which entails that car rental companies are treated as tied agents and therefore are covered by the requirements in the IMD. Based on this we support that the current drafting of article 1(2) is maintained. 5. Increasing the efficiency in cross-border business (D) The Danish FSA supports a clarification of the definition of the freedom to provide services (FOS) and the freedom of establishment (FOE). However since there is no tradition to include these matters in other financial direc-

8 8 tives we believe, that these definitions should be kept in the Luxembourg Protocol of CEIOPS. Denmark has chosen not to be notified when an insurance intermediary operates in Denmark under the freedom to provide services, and we would prefer to be able to continue this procedure under the revised IMD. 6. Achieving a higher level of professional requirements (E) The Danish FSA supports the establishment of basic common principles for professional requirements for all sellers of insurance products. This should be done in order to ensure, that all sellers of insurance have the necessary knowledge and ability to perform their duties. However, we find that it is important that detailed rules concerning the education of insurance intermediaries and employees of insurance undertakings are laid down at a national level. We support the inclusion of a mutual recognition clause in the IMD. However, we also think that it is important, that it is maintained possible for Member States to require additional training of an intermediary if necessary.

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