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The Consumer Voice in Europe
RE: Voting recommendations for the Insurance Mediation Directive
Dear Member of the European Parliament,
BEUC, the European Consumer Organisation, originally welcomed the proposal to review the Insurance Mediation Directive (IMD) in particular as regards the objective to improve consumer protection in the distribution of insurance products through intermediaries.
However, the Econ Committee report still leaves room for improvement on consumer protection issues, in particular with regard to the scope of the Directive, the regulation of the sales of investment based insurance products and out of court redress procedures.
We therefore ask you to support proposals to widen the scope of the Directive by voting to delete the words in article 1, paragraph 2.e, “or provision of a service” and “or theft”, from the text of the proposal and to vote against amendment 3.
We also ask you to facilitate the creation of a level playing field between the sale of insurance-based investment products and other types of investment products, which are regulated under the Markets in Financial Instruments Directive, by voting in favour of amendments 8,9,10 and 11. A failure to align the two regimes creates the risk of regulatory arbitrage. Consumers are using these products to financially secure their retirement and it is therefore of utmost importance to create a regulatory regime that facilitates the sale of appropriate and suitable products to consumers.
We would also urge you to ensure that member states are in a position to continue operating their existing out-of-court redress systems by supporting the request to delete the words “upon explicit and mutual request” from article 13 paragraph 1. The text proposed by the Econ Committee erodes the rights of consumers already in place in some member states.
The Economic and Monetary Committee report contains strong proposals on tying with the potential to enhance consumer protection. We therefore ask you to vote against any proposals to weaken them by voting against amendments 6, 7 and 12.
We remain at your disposal should you wish to receive further feedback.
Greg Van Elsen Financial Services Officer