In the bumpy path of the rewriting of the rules of the financial system, following the systemic crisis of 2008, the transposition into our legal system of the European Directive on the distribution of insurance products (IDD). In fact, the innovations it brings are literally revolutionizing and redesigning the system of relations both between insurance companies and distribution banks and between sellers of the various channels and consumers/investors of insurance products.
Further confirmation of the new wind blowing on the Italian insurance market was the debate recently triggered by a conference held at the Sapienza University in Rome with the collaboration of the National Association for the Study of Credit Problems on the subject of Pog – the supervision governance of insurance products – an aspect highlighted even more by the recent document submitted for consultation by IVASS.
The three essential moments identified by this document were examined and discussed with the coordination of Antonella Antonucci of the University of Bari by as many academics (Ciro Corvese of the University of Siena, Vincenzo Sanasi D'Arpe of the Guglielmo Marconi University of Rome and Alessandra Camedda of the University of Cagliari) respectively on the product approval process, on the distribution activity and on the policy on the governance and control of insurance products, punctually identifying the main criticalities and perplexities aroused by the new regulatory framework.
The subsequent Round Table, the conclusions of which were drawn by Domenico Siclari of the Sapienza University of Rome, gave space to the qualified opinions of representatives of the two Authorities - Ivass and Consob - of the Category Associations - Ania and Abi - and of the insurance world and the banking one. Here are some hints.
Stefano De Polis of IVASS, having clearly referred to the objectives of the new regulation defined in close collaboration with Consob, examined its impact on the internal organization of the Authority itself, on the effectiveness of Pog controls in insurance companies, also verifying their coherence in terms of target market, validity of after-sales control systems and improvement of information flows between producers and distributors.
Adriana Rossetti of Consob for her part, underlining the close collaboration with IVASS, focused on two aspects on which the contribution of this body was spent: the first, linked to the provision of the obligation for subjects authorized to distribute insurance in the 'identify an effective reference market and a negative market for commodities - IBIPs; The second one. linked to the possibility of proceeding with the distribution of IBIPSs to customers who do not belong to the reference market, provided that products meet customer needs.
As for the representatives of the two trade associations, ANIA and ABI, their emphasis was above all on the challenges triggered by the new legislation. On the one hand Luigi Di Falco of ANIA in commenting on the transition to a "customer centric" logic, without of course neglecting the impact of the new legislation on Regulators, highlighted the consequence for insurance companies to broaden their gaze in latitude and longitude to structure products in line with the customer's financial/asset situation and consistent with its life cycle, providing for the provision of consultancy capable of adjusting choices over time. On the other hand Gianfranco Torriero of the ABI highlighted the proactive role of the Association on some crucial aspects such as: the consultancy regime, the responsiveness to the customer's needs, sales outside the reference market, product verification equivalents, the reporting of costs and charges, etc.
At the conclusion of the round of the table, Fabio Carniol from Helvethia Vita and Michela Del Piero from Banca di Cividale spoke.
The first underlined the need for joint governing committees of bancassurance partnerships, as well as the essential role of technical commissions for the agency channel. Furthermore, he emphasized the complexity of the new product governance model which seems to push the market towards a decisive selection, focusing on strategic long-term bancassurance partnerships. Finally, for Carniol, it is necessary both to reconsider the principle of proportionality on which the document in consultation seems somewhat vague, and to urgently implement a sharing of the guidelines of Ania and Abi towards operators to avoid incongruous interpretations and the consequent proliferation of situations of micro-conflict; and finally to resolve the inconsistency that sees products other than IBIPs discriminated against, the placement of which is currently impossible for customers outside the negative and positive target market.
For her part, Del Piero, recalling the importance of the bancassurance project in the current four-year strategic plan of her bank (2019 - 2022), underlined the transversal impact of the POG regulation within her institution with the consequent adoption of an adequate and full-bodied policy. An impact which then had its non-trivial effects on the calibration of the product offer within the ambit of a "customer-centric" strategic vision combined with an improvement in dialogue and in the level of reciprocal attention between the bank and the insurance company. Ultimately, a new exciting challenge for this regional bank which seems to envisage final benefits, not only in cultural terms, capable of repaying the costs of adapting to the new regulatory and operational complexities.
