Response to consultation on draft Guidelines on the use of remote customer onboarding solutions
Go back
It should be noted in particular that the guidelines also address insurers. It is therefore important to keep in mind that the guidelines are also suitable for their business activities. Not all measures that may be appropriate for other financial institutions are equally appropriate for insurers. This could concern particular measures according to 4.4 marginal 46 lit. a), such as checking the account for the customer's account ownership. Insurers usually have no direct way of verifying the ownership of a bank account.
1. Do you have any comments on the section ‘Subject matter, scope and definitions’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.
No specific comment2. Do you have any comments on Guideline 4.1 ‘Internal policies and procedures’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.
No specific comment3. Do you have any comments on the Guideline 4.2 ‘Acquisition of Information’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.
No specific comment4. Do you have any comments on the Guideline 4.3 ‘Document Authenticity & Integrity’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.
No specific comment5. Do you have any comments on the Guideline 4.4 ‘Authenticity Checks’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.
The German insurance industry welcomes a technology-open approach to the guidelines. This is important in order not to hinder the further development of new technological solutions, such as the potential inclusion of AI.It should be noted in particular that the guidelines also address insurers. It is therefore important to keep in mind that the guidelines are also suitable for their business activities. Not all measures that may be appropriate for other financial institutions are equally appropriate for insurers. This could concern particular measures according to 4.4 marginal 46 lit. a), such as checking the account for the customer's account ownership. Insurers usually have no direct way of verifying the ownership of a bank account.