Stellungnahmen

We primarily comment on questions linked to insurance-based investment and pension products. As for former consultations on the PRIIPs KID we clearly stress our criticism of the Reduction in Yield as aggregrate cost indicator being mathematically correct, but not understandable for customers. We propose to replace it by the Reduction in Wealth.

Key Policy Issues on the PEPP Level 2 Regulation are “all-inclusive” cap on costs for Basic PEPP, verifiable guarantee and risk-mitigation techniques as well as reliable disclosure requirements for Key Information Document and Pension Benefit Statement. BdV asks for understandability and comparability with regard to already existing insurance-based investment products for pensions.

The ongoing and even enhanced “low for long” interest rate phase constitute a tremendous challenge for life insurers and their long-term liabilities and will continue to have a severe, more risky impact on their search for yield behavior. Therefore we continue to support EIOPA’s objective to develop principles of a minimum degree of harmonisation in the field of insurance guarantee schemes.