POG Arrangements for insurance undertakings & insurance distributors. October 2016

Transcription

1 POG Arrangements for insurance undertakings & insurance distributors October 2016

2 Insurers and intermediaries need to place consumers at the heart of their business strategies. The tone of this change has to come from the top. These preparatory guidelines will ensure that during 2016 and 2017 supervisors will early engage with the Board and senior managers of market participants to make sure that in 2018 the IDD product governance requirements are in place Gabriel Bernardino, Chairman of EIOPA 2

3 POG arrangements in one shot Main key elements Current situation i The comments from the 2 public consultations have been taken into account The draft guidelines have been consolidated into a final report The final report has been submitted by EIOPA to its Board of Supervisors The final report has been adopted by EIOPA s Board of Supervisors POG time-frame IDD time-frame Who? What? Insurance undertakings Insurance products manufacturers Insurance distributors Why? POG Customer protection in ensuring that insurance products meet the needs of the target market Mitigating mis-selling When? To improve industry reputation due to higher trust by customers Before the IDD enforcement that should happen beginning January 2018 To make insurance undertakings put the clients characteristics, objectives and interests first To provide support and guidance to competent authorities in their preparatory steps leading to a consistent implementation of the organisational requirements on the IDD s POG arrangements at an early stage To enable insurance undertakings to mitigate the risk of different approaches at the national level of IDD implementation and to avoid the need for further alignment for a matter of consistency among member states 2014 Draft of POG guidelines 1 st Public Consultation Draft revision nd Public Consultation POG arrangements Draft revision 2016 POG arrangements Final Report adoption IDD Publication in the EU Official Journal 2017 IDD 2018 Review of the preparatory guidelines IDD transposition deadline 3

4 POG arrangements context Insurance Distribution Directive (IDD) POG arrangements of the IDD Product approval process Product approval process Product design Product manufacturing Product distribution Product monitoring POG Activities Exchange of information Information related to the insurance product and its approval process made available to the distributor by the manufacturer in order to ensure the distributor s understanding of both the products characteristics and the product s identified target market Set-up of adequate arrangements to enhance products information sharing between the products manufacturers and distributors Review of existing products Assessment of their consistency with the identified target market needs Assessment of the distribution strategy appropriateness of these products Responsibilities Insurance undertakings and insurance intermediaries which manufacture insurance products for sale to customers Insurance distributors which distribute insurance products which they do not manufacture Insurance products manufacturers & Insurance products distributors Product approval process The Product approval process should be appropriate and proportionate to the nature of the insurance product and it includes the following activities: Identification of the target market, Source: Final Report Assessment on Public Consultation of the relevant on Preparatory risks Guidelines the target on market product oversight and governance arrangements by insurance undertakings and insurance distributors Consistency check between the intended distribution strategy and the identified target market Ensuring that the insurance products are distributed to the identified target market 4

5 Contact details Deloitte s team Text Thierry Flamand Partner tflamand@deloitte.lu Michaël Cravatte Director mcravatte@deloitte.lu Florent Anders Marie-Aude Lemercier Text Senior Consultant fanders@deloitte.lu Text Business Analyst mlemercier@deloitte.lu

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