This is a major innovation, a robust step, in the wake of the 2008 crisis and the loss of confidence of customers in their financial sector in many advanced economies, sometimes due to deceptive business practices. Restoring confidence is of course in the interest of all those present in this room. This means, for us, ensuring compliance with existing laws and regulations, as well as with the best practices observed or recommended by the ACPR. BIS central bankers’ speeches  1  Naturally, this consumer protection task is not designed to enforce these different rules in a blanket fashion. Rather, it must be done in accordance with the principles underlying these regulations and fully understanding the reality of these business practices. To sum it up in one sentence, these principles aim to balance relations between clients and professionals. This rebalancing is mainly achieved by taking account of the information asymmetry that can exist between these players. This may include rules that are specific to vulnerable clients, to a category of complex products, to the obligation to consider the interest of customers when the product is designed or in the organisation of product distribution. The reality of business practices, however, is difficult to sum up in a few words. This is where the work of ACPR staff comes into play; in the supervision as well as analysis of different data and through contact with both professionals and consumers. Collecting data on business practices is a prerequisite for the ACPR to guide its supervisory duties.
Against this backdrop, the ACPR redesigned its questionnaire on business practices and consumer protection. It can now understand current market practices, as well as trends in products, services and practices. I will now talk about ACPR inspections. They are firstly intended to ensure compliance with the applicable rules and to make sure that errors are corrected before they have consequences for customers. In the worst cases, such errors lead to sanctions. This approach is necessary to punish violations and useful to increase awareness in the profession. ACPR inspections are not however limited to dealing with bad practices on a case-by-case basis. They also identify more general problems that call for changes in market practices or even in regulations. Several examples will be discussed this morning to illustrate the lessons learned from such inspections. For instance, ACPR staff examined distribution channels in which there are a number of intermediaries between the customer and the producer (bank or more often insurer). The questions that we are asking today are simple. But they are important for the sector as a whole. Do all intermediaries provide value added to the customer? How can we guarantee the customer a reliable and efficient chain, irrespective of its organisation? To enhance practices, the ACPR also has a flexible legal tool, the recommendation. I believe that this instrument is useful for prevention. Recommendations are intended to change or guide the behaviour of professionals. It helps them to identify and actually integrate what is expected of them in terms of consumer protection.