The recast of the Insurance Mediation Directive (IMD 2) is coming to a conclusion with the adoption by the Council of the European Union of a new compromise on 28 October (the sixth since May 2014).
The Council has re-qualified the original proposal as the IDD 2, standing for Insurance Distribution Directive 2; one possible explanation for this wording change is to have a broader scope and to cover all channels of insurance distribution and not just intermediaries. Continue reading
FERMA Position paper on IMD2 Continue reading
Florence Bindelle, Executive Manager
The way that EU regulations develop from proposals or green papers into directives some years later is far from transparent and can be very messy. Knowing how to represent the views of risk managers in the right place and at the right time is something that FERMA takes very seriously.
The measures put forward by the EU and its various institutions have an enormous and wide ranging impact on our working lives. Current projects FERMA is monitoring include natural catastrophes, environmental pollution, Solvency II and captives, broker remuneration and the Insurance Medication Directive II, co-insurance and data protection. We are also an official sponsor of the healthy workplaces campaign Working together for risk prevention coordinated by the European Agency for Health and Safety at Work (EU-OHSA).
These are projects which continue to develop, but have been underway for some time. Our aim now is to help our members understand better how EU institutions work. Next year, we’ll be announcing some new ideas, possibly in connection with the general assembly in June.
We ask for our members’ concerns about European matters, primarily through the monthly presidents’ call between FERMA President Jorge Luzzi, and the heads of the national associations. We are also steadily increasing our contacts with EU institutions to raise awareness of FERMA positions, and we join forces with other European associations with similar interests to increase the weight of our views.
We may not make the process of EU law making any tidier but it should be clearer, so the members will be empowered to get their views known where they count.
The passage of European legislation is not fast moving – but at the same time it requires consistent attention to get the views of FERMA’s members to the right people at the right time.
For example, we are waiting for the results of interviews that Ernst & Young are currently conducting on behalf of the European Commission on reinsurance pools and the subscription market. This is part of the Commission’s review of the insurance block exemption regulation (BER), the current version of which is not due to expire until 2017.
More advanced in its progress is the revised Insurance Mediation Directive (IMD) where we are working on a position paper, since the evidence so far is that the Commission does not want to have large risks or professional insurance buyers covered by its provisions. Continue reading
FERMA President Jorge Luzzi looked back at FERMA’s accomplishments over the past year and set out his objectives for FERMA this year in his address to the general assembly held on 3 June in Brussels. Continue reading
The revised European Insurance Mediation Directive (IMD) should incorporate binding standards of transparency for brokers in their relationship with insurance buyers no matter what size the risks. This is the response of the Federation of European Risk Management Associations (FERMA) to the consultation on the revision of the IMD launched by the Internal Market and Services
Directorate General of the European Commission. FERMA’s 19 member associations represent over 4 000 corporate buyers of commercial insurance in 17 European countries. Continue reading