Other

Under Article 2(2) of Delegated Regulation 2017/2359, an inducement is defined as “any fee, commission, or any non-monetary benefit provided by or to such an intermediary or undertaking in connection with the distribution of an insurance-based investment product, to or by any party except customers involved in the transaction in question or a person acting on behalf of that customer”. Therefore, a rebate from a fund manager is considered to be an inducement and the rules governing the payment of such rebates is an inducement scheme. As such, any rebate and terms and conditions governing such rebates must be assessed in accordance with Article 29(2), IDD to ensure that it does not have a detrimental impact on the quality of the relevant service to the customer, and that it does not impair compliance with the insurance intermediary’s or insurance undertaking’s duty to act honestly, fairly and professionally in accordance with the best interests of its customers.Insurance undertakings should also consider EIOPA’s Opinion on monetary incentives and remuneration between providers of asset management services and insurance undertakings in which the risk of customer detriment related to the practice of receiving rebates from asset managers are addressed.