GFIA Letter to the Joint Forum's Consultative document on "Point of Sale disclosure in the insurance, banking and securities sectors"Release Date: 10/18/2013 Staff Reference: Janice Hilchie
Secretariat of the Joint Forum
Bank for International Settlements
Dear Secretariat of the Joint Forum,
The Global Federation of Insurance Associations (GFIA), through its 35 member associations, represents insurers that account for 87% of total insurance premiums worldwide. On behalf of GFIA, I am responding to your request for comments on your consultative document on "Point of Sale disclosure in the insurance, banking and securities sectors."
We very much appreciate the opportunity to provide input.
We support the overall objective of the Joint Forum's paper. Clear disclosure about key characteristics of products, received prior to the sale, is important to consumers in helping them make informed decisions. The paper quite rightly observes that significant differences in products and in regulatory approaches may not facilitate comparison across products, and therefore, what is important is "the outcome, not necessarily the method by which the outcome is achieved". Many of our specific comments relate to the importance of retaining that awareness so that consumers are provided with relevant information.
We understand that this paper is not intended to be binding on any jurisdiction, but rather to set out recommendations that could be considered in developing or modifying POS disclosure regimes. It is important to keep in mind that various jurisdictions are in the throes of developing, revising or implementing a regime1, and there may well be inconsistencies and contradictions between these and the Joint Forum recommendations. It may be worthwhile to reinforce the point that the recommendations should be viewed as a resource or "inspiration tool". As well, in order to avoid any misinterpretation that the recommendations are intended to impose requirements, consideration should be given to making the language in the paper less prescriptive, e.g. use "may" instead of "should".