Insurance Europe has published its response to ESMA’s call for evidence on aspects of retail investor protection.
Key points in the response include:
- insurance-based investment products (IBIPs) account for c.90% of the current PRIIPs market (which accounted for around €5 trillion of assets under management in 2019), so it is vital that the future framework respects IBIPs’ specific features and enables consumers to take better informed decisions;
- the EC Retail Investment Strategy should examine how to better explain the characteristics of different products, rather than adopting a common approach for all financial products;
- the regulatory framework must be digital-friendly for all products and services;
- action is needed to increase financial literacy across Europe and the Commission should play a greater role in achieving this; and
- any review should not be rushed – extensive technical and consumer testing and an adequate timeline for the consultation of stakeholders are essential.