Insurance Mediation Ordinance

“What are the implications of the forthcoming Financial Intermediaries Regulations for intermediaries’ VSH cover?”

In § 9 paragraph 2 of the forthcoming FinVermV, reference is made to § 9 paragraphs 2 to 5 of the Insurance Mediation Ordinance.


This currently means the following for the amount of insurance coverage:

“The minimum sum insured is 1,130,000 euros for each insured event

and 1,700,000 euros for all insured events in one year”.


According to the legislator’s estimate, the “bancassurance intermediary” will incur costs of between EUR 800 and EUR 1,200 for such cover.


The biggest problem with this is that (similar to insurance intermediaries or, say, tax advisors) this does not protect the

consumer from criminal conduct or gross breach of professional duties (so-called knowing breaches of duty),

because in such constellations the compulsory insurance does not provide any insurance cover.


The FinVermV will be implemented alongside the associated law “zur Graumarktregulierung” (Law on the Amendment of the Financial Investment Intermediary Act).

and investment law) will lead to a further thinning out of the “free” intermediary community, i.e. to further market concentration.


Those who want to be better insured as a financial intermediary, that is, to avoid some gaps in coverage,

will have to seek supplementary insurance cover.


In addition, it is to be expected that clients – in the knowledge of the VSH cover – will increasingly try,

to sue the financial intermediary in the event of misadvice.


Dr. Johannes Fiala

(DHBW Newsletter 11-2011)

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Dr. Johannes Fiala Dr. Johannes Fiala

Dr. Johannes Fiala has been working for more than 25 years as a lawyer and attorney with his own law firm in Munich. He is intensively involved in real estate, financial law, tax and insurance law. The numerous stages of his professional career enable him to provide his clients with comprehensive advice and to act as a lawyer in the event of disputes.
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