Question ID: 1641 - Clarification of Article 16(d)'s unreasonable customer detriment due to charges
Regulation Reference: (EU) No 2017/2359 - info requirements and conduct of business rules applicable
Topic: Other
Article: 16
Status: Final
Date of submission: 10 Jul 2018
Question
Article 16 of Delegated Regulation 2017/2359 - can EIOPA provide some practical examples for the notion “unreasonable detriment to the customer because the charges are disproportionate” in (d)?
EIOPA answer
This refers to the relationship between the actual cost of surrender to the insurance undertaking and the administrative cost of surrender actually charged by the insurance undertaking. The latter should not be disproportionate to the former or otherwise used to generate profits (see also the Q&A on the term “legitimate costs”) as an insurance undertaking.