Problems Encountered by Consumers in Property Insurance SEMINAR FOR STAKEHOLDERS PRODUCTS, POLICIES, REGULATIONS AND CONSUMER CONCERNS RELATED TO PROPERTY INSURANCE IN FIJI Thursday, 11th August 2016

Presentation Outline Disclosure Requirements Engineering Cyclone Certificate - Requirements Policy Reform Considerations – RBF Standard Code of Conduct Publication of Information Consultations Enforcement Inclusive Insurance Market for Vulnerable groups? Conclusion

Disclosure Requirements Pre-disclosure Statements for Insurance Contracts in Fiji Pre-contractual disclosure – Consumer Credit Act – section 14 Comparison to the Australian mandatory PDS Highlight the need for PDS in Fiji???? Important disclosure for consumers to make an informed decision / comparative shopping before they decide to sign up!!

Disclosure Requirements Pre-contractual disclosure – Consumer Credit Act – section 14 Comparison to the Australian mandatory PDS Highlight the need for PDS in Fiji???? Important disclosure for consumers to make an informed decision / comparative shopping before they decide to sign up!!

Disclosure Requirements Role of The Insurance Council to generally inform / educate consumers on everything to do with insurance products and practices in Fiji??? Compare the IC-A with the IC-NZ (neatly stacked – consumer friendly information) to the IC-FIJI flimsy Facebook page that has no content whatsoever.

Engineering Cyclone Certificate - Requirements Why the need for maximum requirements for consumers? Maximum requirements make the structure full proof – defeating the purpose of insurance cover? Regulator sets minimum standards governing insurers through insurance supervisory statement but allow for maximum requirements for consumers? Talking points: Ian McCallen Case Rogue Enginner Case

Policy Reform Considerations - RBF RBF to standardize and implement code of conduct for agents, sub agents instead of leaving it to the insurance companies, agents and sub-agents to draft their own policies. Why no standard? Insurance Supervision Policy Statement No. 7 - Fit and Proper Requirements for Insurance Companies and Insurance Brokers in Fiji - objectives of policy – 2.1 (ii))set out a minimum standard which can be used by insurers and brokers when determining whether a person holding a key position within an institution (responsible person) is fit and proper;” RBF to publicize information for consumers benefit and knowledge in stead of withholding information from consumers Insurance Supervision Policy Statement No. 9 – Policy Guideline on Complaints Management – Intro – 1.2 “The publication of complaints through the media may damage the reputation of insurers in the public eye and could erode public confidence in the Insurance Industry if complaints are not handled with proper procedures.” It is important to note that most of these policies have been implemented from 2008 to 2014. The regulator has introduced some 12 insurance supervision policy statements. Minimum Requirements for the Appointment and Supervision of Insurance Agents in Fiji. Fit and Proper Requirements for Insurance Companies and Insurance Brokers in Fiji; Policy Guidelines on Complaints Management; Minimum Guidelines on Complaints Management; Disclosure Requirements for Licensed Insurers in Fiji;

Policy Reform Considerations - RBF Insurance Companies must inform consumers of change in t & c in insurance policies – Law is silent on consultation with the consumers - only consultation between Insurer and regulator for their approval. When Insurance companies amend policies, there is a commercial obligation on them to CONSULT with the insured of the amendments. In any case, any unilateral amendment of policies should, by law, declared illegal. Insurers need to be more vigilant when it comes to renewal of policy information sent out to consumers and not be erroneous with information. The law provides for renewal notices to be sent to consumers. Accuracy of information is a must! Unfortunately, this has been happening. If the terms of a contract are changed in a renewal notice without notifying the insured, then this would cause a problem. It is this that needs to be declared illegal.

Policy Reform Considerations - RBF RBF to BE INCLUSIVE and consult the people – to take into consideration submissions from the people / organized groups when drafting policies that will affect consumers. Consumers Voice has to be heard and made to count! Ref. Insurance Supervision Policy Statements by RBF RBF to enforce law and policies – consumers need to see that justice is being carried out. There must be visibility with this. Perhaps RBF would like to share statistics or precedents on cases (and issues) they have taken insurance companies to task? Ref. page 3 of the Insurance Industry Report (if asked on consultations by RBF??)

Inclusive Insurance Market for Vulnerable groups? Revisit the need and underlying purpose/ premise of Insurance Cover Are the vulnerable groups in Fiji being protected? Why is it now near impossible to obtain flood covers for flood prone areas? How can we formulate policies to incorporate cover for the poor and disadvantaged? Natural Disasters will happen because of Climate Change – We need to prepare ourselves for that!!!

Conclusion Consumers demand more accountability, transparency and inclusiveness in the current Industry practices. The regulator needs to take a more pro-active stance and create a more visible presence with the public in its enforcement of the Insurance Laws, Regulations and Policies already in place. Any reforms by RBF must be inclusive of consumers and not a ‘behind the scenes’ approach solely between the Insurance providers and the regulator only.

Problems Encountered by Consumers in Property Insurance SEMINAR FOR STAKEHOLDERS PRODUCTS, POLICIES, REGULATIONS AND CONSUMER CONCERNS RELATED TO PROPERTY INSURANCE IN FIJI Thursday, 11th August 2016