IMD2 – a challenging improvement Daniela GHETU Editorial Director XPRIMM Pubications

The fundamental issues January 2010 – The European Commision launched a call for advise regarding the IMD revision “the implementation check of the IMD conducted by EC has shown that, as a result of the minimum harmonization introduced by the IMD, the practical application of its provisions varies between Member States. [...] In addition, gold-plating practices as well as the use of general good requirements at national level, create undesirable obstacles to the functioning of the Single Market for insurance and reinsurance intermediaries”.

The fundamental issues IMD2 - a simple Directive or a Lamfalussy Structure? The scope of insurance mediation to be covered by IMD2 - conditions for exemption from IMD2 Setting the high level requirements on knowlegde and ability of insurance intermediaries Improving the notification system Improving the conflicts of interest management - issues as the differences between PRIPS and the other types of insurance products, transparency of remuneration etc. Reducing the administrative burden of the IMD implementation

Consultation process Large number of entities involved: EIOPA (ex-CEIOPS), BIPAR, CEA, consumer associations etc. December 2010 – Bruxelles – Public Hearing on the opinions expressed during the consultation process

First details on the future design The European market needs a consistent approach for the regulation of the sale of investment products. Also, more transparency, a level playing field for all the insurance distribution channels and better tools to build consumer confidence in the Single Market. Karel Van Hulle Head of the Insurance and Pensions Unit, European Commission - Directorate-General “Internal Market and Services”

First details on the future design IMD2 will: retain the activity-based definition of insurance intermediation and it should try to clarify the exemptions from the scope of the Directive. extend the scope of the IMD to direct sales by insurance undertakings keep the Reinsurance intermediaries in the scope of the IMD keep the current registration regime but it will try to simplify

First details on the future design More transparency is needed in the relationship between intermediaries, customers and insurance undertakings. Remuneration – the “hot potato” The “disclosure upon request” system seems to be favourite solution at this level Professional requirements and training – almost unchanged

First details on the future design More transparency is needed in the relationship between intermediaries, customers and insurance undertakings. Remuneration – the “hot potato” The “disclosure upon request” system seems to be favourite solution at this level Professional requirements and training – almost unchanged

First details on the future design Although it may be desirable, a total harmonization of legislation in member countries regarding the functioning of the insurance brokerage market is not yet possible, given the very high costs which this would imply. Sharon BOWLES President of the Economic and Monetary Affairs Committee of the European Parliament IMD2 = unity in diversity?

Thank you ! Daniela GHETU Editorial Director XPRIMM Pubications