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BackThe AK welcomes the fact that the Commission as part of the revision of the Insurance Mediation Directive (in short: IMD) is aiming at strengthening consumer protection and we share the opinion of the Commission that need for action exists with regard to conflicts of interests and in particular in respect of commission and cost transparency.
Apart from that, the AK also supports raising the standard of professional requirements for mediators. However, the simultaneous revision of several Directives (MiFID, IMD) as well as the PRIPS Initiative (on Packaged Retail Investment Products), which are directly connected as to contents and which contain many cross references in the Commission documents make the evaluation of individual issues of the present Consultation more difficult. Given the fact that the MiFID is also being revised, the so-called “benchmark role” of MiFID for the revision of the IMD, which has been named in the discussion, is not quite clear in our opinion. <br /><br />
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Christian Prantner
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Benedikta Rupprecht
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