POG Arrangements for insurance undertakings & insurance distributors. October 2016

POG Arrangements for insurance undertakings & insurance distributors October 2016 “Insurers and intermediaries need to place consumers at the heart ...
124 downloads 0 Views 160KB Size
POG Arrangements for insurance undertakings & insurance distributors October 2016

“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

© 2016. Deloitte Touche Tohmatsu Limited

2

POG arrangements in one shot Main key elements

i

Current situation •

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? •

Insurance undertakings



Insurance products’ manufacturers



Insurance distributors

What? •

Customer protection in ensuring that insurance products meet the needs of the target market



Mitigating mis-selling

POG When?

Why? •

To improve industry reputation due to higher trust by customers



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

© 2016. Deloitte Touche Tohmatsu Limited



Before the IDD enforcement that should happen beginning January 2018

POG arrangements 2014

2016

2015

2017

2018

POG arrangements 1st Public Consultation

2nd Public Consultation

Review of the preparatory guidelines

Final Report adoption IDD

Draft of POG guidelines

Draft revision

Draft revision

IDD Publication in the EU Official Journal

IDD transposition deadline

3

POG arrangements’ context

Insurance Distribution Directive (IDD) POG arrangements of the IDD Product approval process

Product design

Product approval process

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 on Public Consultation on Preparatory product oversight and governance arrangements by insurance undertakings and insurance distributors • Assessment of the relevant risks to Guidelines the targeton market • Consistency check between the intended distribution strategy and the identified target market • Ensuring that the insurance products are distributed to the identified target market © 2016. Deloitte Touche Tohmatsu Limited

4

Contact details Deloitte’s team

Thierry Flamand Partner

Text

[email protected] +352 661 451 469

Michaël Cravatte Director [email protected] +352 661 451 884

Florent Anders Text

© 2016. Deloitte Touche Tohmatsu Limited

Senior Consultant

Marie-Aude Lemercier Text

Business Analyst

[email protected]

[email protected]

+352 661 451 922

+352 621 568 495

5

Deloitte is a multidisciplinary service organization which is subject to certain regulatory and professional restrictions on the types of services we can provide to our clients, particularly where an audit relationship exists, as independence issues and other conflicts of interest may arise. Any services we commit to deliver to you will comply fully with applicable restrictions. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. About Deloitte Touche Tohmatsu Limited: Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see www.deloitte.com/about for a more detailed description of DTTL and its member firms. Deloitte provides audit, consulting, financial advisory, risk management, tax and related services to public and private clients spanning multiple industries. Deloitte serves four out of five Fortune Global 500® companies through a globally connected network of member firms in more than 150 countries bringing world-class capabilities, insights, and high-quality service to address clients’ most complex business challenges. To learn more about how Deloitte’s approximately 225,000 professionals make an impact that matters, please connect with us on Facebook, LinkedIn, or Twitter.