December 10 marked the end of the AMF's consultation on its proposed regulations for alternative distribution methods.

In its position paper, the RCCAQ focused on the need to maintain a high level of consumer protection and advisory services at each step of the insurance buying process, regardless of the distribution method selected. While the RCCAQ subscribes to the spirit of the new regulations, we have raised the following questions and points requiring further analysis in the following four areas:

• The roles and responsibilities of certified representatives, which give rise to various questions, including the notion of "mixed" or hybrid transactions (i.e. when clients use an online distribution channel as well as a certified representative).

• The requirements of a high level of oversight, across a series of points requiring further analysis, including verifying the identity of the online client or the need to give consumers access to comprehensive information.

• Control and monitoring measures, which are designed to swiftly detect issues relating to personal data protection for consumers and to rectify, as needed, any shortcomings specific to the online distribution channel.

• Issues relating to distribution without a certified representative, which online insurance sales will make more complicated, particularly if a distributor submits an insurance request on behalf of a client.

The RCCAQ continues to offer the AMF its full cooperation in this regard.
For further information and to access the RCCAQ's position paper, please click here.