Regulatory Alerts2023-06-14
Guidance Notice 01/2023 on Conduct of Business Supervision for Savings Products
BaFin has issued Guidance Notice 01/2023 requiring German and cross-border life insurers to conduct independent assessments of the value for money of their distributed savings products under the Insurance Distribution Directive. The notice mandates that insurers define target markets, evaluate the interaction of costs and returns through scenario analyses, and ensure appropriate pricing for intermediary remuneration, lapse expectations, and unit-linked fund reimbursements. By aligning with EIOPA’s methodology, BaFin shifts the supervisory focus from direct product regulation to verifying that insurers’ internal product approval processes consistently deliver appropriate value for money to policyholders.
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