Stellungnahmen

FinTech, including InsurTech and Robo-Advisors, may be a factor for a more competitive and innovative European financial sector. But BdV underlines that consumers and investors must always be able to continue relying on high standards of consumer and investor protection, of data protection and privacy rights and of legal responsibility on the part of financial services providers.

BdV welcomes Guidelines on complex IBIPs but emphasizes the need for strict criteria. If too many exemptions from the suitability and appropriateness assessments are made, there will not be any changes in distribution practices of life insurances.

BdV fully supports EIOPA’s objective to develop a principle-based minimum harmonisation of recovery and resolution frameworks for insurers available to all national supervisory authorities. This objective is clearly consistent with the objectives which are already implemented in other sectors of the financial industry.