Response to consultation on Professional Indemnity Insurance (PII) for mortgage credit intermediaries

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Do you agree that, of the four options presented, option 4 (i.e. setting the minimum amount at the average of the amounts used in Member States) is the option the EBA should pursue, resulting in a minimum amount of EUR 584 000 per claim, and EUR 886 000 per year?

Third party liability insurance or comparable guarantee, covering damages caused by mortgage credit intermediaries with regard to their business activity, are not mandatory in Poland. Insurance companies haven’t got loss experience on this type of insurance. There should be taken into account that lack of know how about risk assessment and premium calculation might cause difficulties to offer appropriate insurance product. Mortgage credit intermediaries may have a problem with running activity (continuing or starting). If the main obstacle turns to be guarantee sum, any change for a need of particular member firstly will require more complicated procedure than a change of local law and secondly will be effective towards all members.
It must be remembered that the same guarantee sum will be in force in all member states regardless of local specificity governing credit intermediary market, real estate prices, legal background and in particular loss experience of each member. An experience of local insurance market may differ from each other. Therefore we will recommend to introduce the lowest guarantee sum and to authorize member states to establish an adequate sum on local level according to market conditions of each member.

Do you consider the number and the compensatable loss of compensation claims arising from the activity of mortgage intermediation to be lower than, the same as, or higher than those arising from insurance intermediation? Please explain your reasoning.

There is no sufficient data to answer to the question.

Do you know of options other than those listed in this consultation paper that the EBA should consider when deciding on the minimum amount of coverage?

We don’t have knowledge about other option.

Do you consider threshold(s) that distinguish between more than one minimum amount of PII coverage to be a desirable feature? If so, please explain how such a threshold should be devised.

There is no sufficient data to answer to the question.

Name of organisation

Polish Insurance Association