recurring defects in the presentation of the products

Regulators on Thursday called on professionals selling online savings products to improve their practices, noting “numerous cases of non-compliance with regulations concerning customer information and informed consent”.

An imbalance between the presentation of the advantages and the risks inherent in subscribing to the product or service has been too often noted in the advertisements, noted the Autorité des marchés financiers (AMF) and the Autorité de Contrôle Prudentiel et de Résolution ( ACPR) in their work. In addition, it was noted that certain actors presented first of all the advantages of the productthen the subscription links, before the risks inherent in the latter, continue the regulators, noting that this can be considered a practice that does not promote informed consent.

The ACPR and the AMF have also noted that the pre-contractual information was not accessible enough because scattered in several places on the site or on different documents. In the majority of cases, it was observed by the testers that the general conditions could be long, dense, technical and not very attractive (…) creating a repulsive effect on the existing or potential customer, point out the regulators.

heterogeneous questionnaires

Regarding the collection of customer information, the survey revealed very heterogeneous questionnaires. For example, among the investment objectives that the client must select, many do not systematically include short-term objectives, which are not very compatible with the subscription of a life insurance policy, yet their presence in these questionnaires precisely allows ofalert the subscriber of a possible incompatibility of the product envisaged with his requirements and his needsreprimand the regulators.

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To conduct this study, the ACPR and the AMF consulted financial institutions, consumer associations and mediators. They then carried out consumer tests and interviewed real customers.

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