FERMA is concerned that the revised version of the Insurance Mediation Directive does not treat all insurance buyers equally particularly when it comes to standards of disclosure. In the current version of IMD2, only individual policyholders and small businesses would be entitled to disclosure of their intermediary’s remuneration.

For buyers of insurance for large risks and professional customers, disclosure is voluntary. And while professional customers may request disclosure in writing, a proposed amendment to IMD2 would remove even this protection.

According to FERMA President Jorge Luzzi, “Voluntary disclosure works well in a number of countries…but…not all business insurance buyers are in a position to negotiate full disclosure.” FERMA is calling on the European Parliament to make sure that ALL insurance buyers are included in IMD2…and at minimum; all should have an enforceable right to request the information.

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