Insurance Europe has submitted its response to the EC consultation on its proposal to repeal the Directive on Distance Marketing of Consumer Financial Products (DMD) and to introduce a new section on distance marketing of financial services in the Consumer Rights Directive (CRD) regarding financial services contracts entered at a distance.
Insurance Europe is generally supportive of the European Commission’s intention, although it would be preferable to transfer the remaining provisions of the DMD to sector-specific legal acts.
The sector agrees that the provisions in the DMD have, to a large extent, been replaced and made redundant by provisions in more recent product specific and horizontal EU legislative acts.
On the introduction of a withdrawal button, Insurance Europe has expressed its concerns over how to operate these in practice, and raised concerns over whether they would increase the risk of consumers finding themselves to be uninsured – particularly in the context of mandatory insurance.
Insurance Europe is also concerned that the proposed one-day waiting period does not meet consumer demand for quick and seamless processes when purchasing insurance protection at distance.
Feedback received by the EC from stakeholders will be summarised by it and presented to the European Parliament and Council with the aim of feeding into the legislative debate.