각국 보험가입보조자에 대한 비교연구

Abstract

It is usual that insurance consumers make contracts with in insurers through intermediaries such as insurance agents insurance brokers Such intermediaries sometimes commit unlawful acts in selling insurance which might cause signbificant losses to insurance consumers. Therefore a relevant regulatory regime about insurers intermediaries is necessary. However there are some differences surrounding the regime among countries such as the U.K, the U.S., Japan , German and Korea. First the U.K, U.S., Japan and Korea take a system regulating strongly insurance intermediaries while German does not However this difference will disappear soon as German is due to introduce a strong regulatory system in 2005. Second the U.K. integrated all kinds of intermediaries including insurance intermediary under the Financial Services and Markets Act 2000 while the U.S. Japan German and Korea still maintain separate regulatory system The position of the U.K. seems relevant and efficient in that the boundaries among financial products become blurred packaged financial products become common the same function performed by intermediaries must receive the same regulation Third the U.K the U.S., Japan regulate all kinds of insurance intermediaries while Korea does not regulate the employees of the insurer. It is suggested that kora follow the former countries.