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2
Feedback to the Public Consultation I
General comments
- Importance of POG arrangements acknowledged
- Inappropriate timing in view of IDD
- Causing the risk of inconsistencies
- Additional burden for industry
- Beyond POG rules of IDD
possible amendments Frankfurt, February 2016 Feedback to the Public - - PowerPoint PPT Presentation
possible amendments Frankfurt, February 2016 Feedback to the Public - - PowerPoint PPT Presentation
Draft preparatory Guidelines on POG arrangements Public Consultation Feedback and possible amendments Frankfurt, February 2016 Feedback to the Public Consultation I General comments Importance of POG arrangements acknowledged
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3
Feedback to Public Consultation II
Major concerns
- Scope
- Retroactive application
- Principle of proportionality
- Request for more clarity on “detriment”
- Redundancy of GL 4 (obtaining all relevant
information from manufacturer)
- Distribution outside of the target market
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4
Possible amendments
- Clarification on the retroactive application
- Specification of the principle of proportionality
- Amendments on the issue “distribution outside of
the target market”
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5
Next steps
- WS to finalise the analysis, to revise draft GL and
to draft final report on public consultation
- Submission to BoS in April for approval
- Following translation of POG Guidelines
- “Comply or explain” mechanism
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6
Comments
- r
Questions?
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