The Association of International Life Offices (AILO) is the representative organisation for life insurers operating cross border in the EU under the ‘Freedoms’. Members are only involved with international, cross border operations and represent true “Single Market” players. Accordingly, AILO has been consistently involved with the development of PRIIPS since 2007, when it first appeared in the form of “substitute products”.
AILO has read the European Commission’s letter to the Joint ESAs regarding a “quick fix” to the rejected RTS and the solutions it proposes to the ESAs. Our understanding is that the choice of a Regulation as the instrument for PRIIPs was to ensure it would be impossible for any Member State (MS) to ‘gold plate’ or otherwise amend the Level 1...
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