1
DANISH SHIPOWNERS' ASSOCIATION
28 January 2011
Response to the Commission’s consultation document on the Review of the Insurance Mediation Directive (IMD)
Information about the respondent
Name of respondent organisation/company/natural person:
DANISH SHIPOWNERS' ASSOCIATION
Amaliegade 33
DK-1256 Copenhagen K
DENMARK
Interest Representative Register ID:4518600611-48
Contact person and function:
Dorte Rolff, Head of Department (Legal), Lawyer
E-mail:
Tel.: +45 33 11 40 88 / Direct tel.: +45 33 48 92 85
Country:
Denmark
Dear Sirs,
The Danish Shipowners' Association thanks the Commission for the opportunity to provide a response to the Commission's Review of the Insurance Mediation Directive (IMD).
We are generally in agreement with the Commission's Consultation document. Regarding the specific points we would like to comment as follows:
Regarding 3.1 – Policy objectives
A. A high and consistent level of policy holder protection embodied in EU law
A.1
We agree to both questions.
A.2
The exemption from information requirements for large risk insurance products as laid down in Article 12 (4) of the IMD should not be retained since the information required would also benefit buyers of large risk insurance.
A.3
We are in favour of harmonisation and hence do not believe that the possibility for Member States to impose stricter requirements should be maintained.
A.4
We do not believe a definition of "advice" should be introduced. We believe it has advantages that "advice" is a flexible concept bearing in mind all the different kinds of insurance it applies to.
A.5
See A.4.
A.6
N.a.
A.7
N.a.
B. Effective management of conflicts of interests and transparency
We concur with the Commission's statement in the box and have no further specific comments.
C. Introducing clearer provisions on the scope of the IMD
We are in favour of the Commission's statement in the box. However, we believe that the IMD Article 1 exemption should be broadened by deleting point c according to which liability insurance in any form cannot be exempted. Our shipowner members would potentially like to offer cargo insurance, a standard and simple form of insurance, but cannot do so outside the scope of the IMD as it stands.
D. Increased efficiency in cross-border business
We concur that cross-border insurance intermediation needs to be more effective.
E. Achieve a higher level of professional requirements
Whereas we support basic common principles for professional requirements for all sellers of insurance products, we do not support an actual examination or the like.
Regarding 3.2 – Distribution of insurance PRIPs (investments packaged as life insurance policies)
No comments.
Yours faithfully,
DANISH SHIPOWNERS' ASSOCIATION
p.p.
Dorte Rolff