Stellungnahmen

BdV strongly welcomes EIOPA’s proposal of the two-step process to assess the suitability of the insurance-based investment product. With regard to the “sustainability preferences” of the policyholder (the initial questioning and the necessary information about them) we support EIOPA’s “layered” approach presented by these guidelines as well balanced and pragmatic.

In its comments for this consultation on insurance-based investment products BdV stresses again that "product complexity" must not be limited to the "criteria originating from the securities market", but should include the opaque combination of investment part and biometric risk coverage. Additionally we ask for actual "independent" advice and better understandable cost indicators.

BdV supports the inclusion of past performances, asks for enhanced supervision of contradictory assessments of summary risk indicators and advocates information layering for multiple options products. Generally spoken there is a strong need for monitoring “value for money” and enhanced supervisory convergence.