The AMF consultation on alternative distribution methods (online insurance sales and distribution without certified representatives) concluded on December 10.

In keeping with its active role in discussions on the development of an effective regulatory framework, the RCCAQ submitted a position paper entitled "Assurer un niveau élevé et égal de protection du consommateur" [Ensuring a high and equal level of consumer protection].

Drafted with the help of our legal team, the position paper included the RCCAQ's comments on the AMF's draft regulations, based on the deliberations of the member advisory committee.

The comments of all consultation participants will be made public by the AMF. In the meantime, RCCAQ members can be the first ones to read the position paper by accessing the members-only section of our website.

The RCCAQ's comments are primarily based on four main areas of concern:

• Certified representatives' roles and responsibilities have prompted a number of questions relating, among other things, to "mixed" or hybrid transactions in which clients use an online distribution channel as well as contacting a representative.
• The requirements associated with a high level of oversight have raised a number of points as well, including verifying the identity of online clients and ensuring that consumers have access to comprehensive information.
• Control and monitoring measures are aimed at swiftly identifying issues relating to the protection of consumers' personal data and rectifying the shortcomings of online distribution, as applicable.
• The issue of distribution without certified representatives, which has been complicated by online insurance sales, particularly since it is assumed that distributors will complete insurance applications on behalf of their clients.

If you have any questions or comments, please send us an email (communications@rccaq.com).