2015 Star Ratings. Car Insurance. Discussion paper

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1 2015 Star Ratings Car Insurance Discussion paper Defaqto Limited All rights reserved. No parts of this publication may be reproduced in any form by any means, whether electronic, mechanical, optical or any other or be stored in a retrieval system without the express written permission of the publisher. The publisher has taken all reasonable measures to ensure the accuracy of the information and Ratings in this document and cannot accept responsibility or liability for errors in or omission from any information given and for any consequences arising.

2 About this document This document outlines the key developments and trends that will inform the criteria we use for the 2015 Star Ratings for Car Insurance and, based on these, sets out the areas where we would like to consult the industry as part of ensuring that our ratings process remains robust and transparent. 2

3 Key developments and trends The market We have reviewed developments in the car insurance market, considering legislation and regulation, provider changes, and car insurance products and propose the following changes to our Ratings for 2015: The FCA investigation into the sale of add-on insurance is likely to change the focus of the relative importance of these policy add-ons; we intend to reduce the amount of emphasis placed on the quality of the add-on products in our ratings The use of telematics in car insurance continues to grow. There are now 20+ products with a telematics process either being compulsory or providing discounts for their use. We do not intend to change our Rating criteria this year as a result of this change, but we will be monitoring this market development closely for future years Legislation and regulation There are two major developments in this area at present, the FCA investigation on the sale of 'add-ons' and the OFT investigation into the private motor market. FCA Review into policy add-ons The major development in this area at present is the FCA investigation on the sale of 'add-ons and we have considered the provision of two of the major add-ons to Car insurance, Uninsured Loss Recovery and Breakdown cover. Over the past six years the availability of uninsured loss recovery cover has been fairly consistent, although almost a third over cover as a standard benefit in 2014 Over half of policies still sell Uninsured Loss Recovery as an optional extra Uninsured loss recovery cover (% of policies) 49% 53% 27% 17% 23% 30% Cover is standard Cover is optional Cover not provided We believe that the important question with uninsured loss recovery is whether cover is available, irrespective of it being included as standard or as an optional extra, as this is usually simply an issue of cost We believe that the importance lies with the indemnity limit provided rather than the availability. We intend to include criteria for uninsured loss recovery cover within the 2015 Star Rating based on this factor, and remove whether this is available as standard or as an optional extra, thus focusing on the cover rather than the element of cost 3

4 We also looked at the change in the provision of breakdown cover over the past six years: During this period the availability of UK Breakdown cover has changed significantly with the number of policies including cover as a standard benefit increasing from 7% in 2009 to 16% in 2014 The number of products that do not offer cover has reduced from just under half of all policies in 2009 to a third in 2014 UK Breakdown Cover (% of policies) 49% 33% 44% 51% 7% 16% Cover not provided Cover is optional Cover is standard We intend to score as availability of cover based on whether both EU and UK cover is available or just EU or UK only OFT review into the Private Motor market We looked at the possible outcomes of the OFT review of the private motor market, the emphasis of which is on claims management process: The final outcome of this review is due to be report by 27 September 2014 We don't believe there is currently any need to change any DNA scoring or our methodology as a result of this review Providers We reviewed how the make-up of distribution has changed over recent years, comparing 2014 to 2009: Total distributor numbers have increases remained fairly static over the period, with 158 distributor brands today compared to 151 in This summary figure masks some major changes though 43 of the distributors in 2009 were no longer selling car insurance as at of the distributor brands in 2014 did not exist in 2009 We are seeing the return of recognized insurer brands, e.g. General Accident, Legal & General etc. Despite the dramatic change in distribution we cannot detect any marked change in the overall types and quality of cover being offered, so feel no need to change our Star Rating criteria on this account Products/propositions We looked at the way in which providers' products and propositions are changing over time: 4 Product numbers have remained fairly static over the period with 232 available in 2014 compared with 223 in 2009 Over recent years there has been an increased in the focus on Accident Management Services Mobile technology is increasing with the availability of Mobile Apps for claims management and customer communication

5 There is an increasing mandating of Telematics devices, or premium rewards for using them; and a possible developing trend of encouraging the use of dashboard cameras None of these is yet sufficient for us to amend our Star Ratings criteria for

6 Key implications for the 2015 Ratings process Product area weightings The criteria have been split into the following areas in order to show the weightings for each within the Ratings: Rating area 2014 no. of features 2014 % share of features 2015 no. of features 2015 % share Policy Cover Accident Management Services Policy Cover Availability Policy Excesses/Terms Policy Add-ons Helpline Services Total We will continue to place most of the emphasis on the policy cover provided and accident management services, which account for over two-thirds of the criteria used. What does good look like? For 2015 we do not see a need to change the current core criteria for 4 or 5 Star products from those which are currently being applied, although we are proposing to add new car damage (%) as an additional core criterion for 5 Star products. Rating area Core criteria set for the following Policy Cover New Car Damage (%) Windscreen Limit Personal Belongings Theft of Keys NCD Protected Claims Accident Management Services Car Rescue Cover Class of Courtesy Car Repairs Guarantee Helpline Services Emergency Helpline 6

7 Areas for discussion These are the areas where Defaqto would like to discuss their proposals, and receive any feedback that you might have. Changing the DNA scoring method for add-on features to reflect only the quality of the addon, rather than the price bundling of the feature Driven by our view of the likely market changes as a result of the FCA review into the sale of 'Add-ons'. This will lead us to remove the ULR cover as a criterion from the 2015 Star Rating criteria Amendment of criteria for EU and UK Breakdown with a move away from scoring "optional" and "standard" as a DNA score of 3 and 5, and consideration only to the availability of cover. Therefore if cover is available for both EU and UK a DNA score of 5 applies, for products that offer EU or UK only a DNA score of 3 will be given Reflect on the cover and limits, rather than the availability of cover and reduction of excesses within the criteria We are also proposing to remove how certain cover features are provided and only reflect on the cover basis and limit provided. This will lead us to remove loss of keys and theft of keys cover as a criteria for 2015 We have reviewed the current excess criteria used within the current criteria and this has lead us to propose to remove inexperienced driver excess as a criterion No changes to the 2015 Star Rating criteria as a result of the increasing of telematics This market is still in its infancy There are insufficient telematics product features to warrant their inclusion at present Inconsistency between the insurer offerings means products may not yet be fairly comparable on a like for like basis No changes to claims management criteria as a result of the OFT review The possible recommendations by the OFT are unlikely to directly impact on product features of car insurance, and are more likely to be related to cost control and insurer behaviour No other changes to product features studied We carried out a major review of our DNA scores for 2014, and haven't seen any dramatic market changes that would require us to reconduct this review for 2015 Ratings There are no obvious elements of policy cover that might emerge over the next 16 months We cannot see any reason to remove any of the existing elements of cover from our ratings because of market changes likely to happen in the next 16 months 7

8 Appendix: Proposed 2015 criteria Based on the above analysis, we propose including the following criteria in our assessment process for the 2015 Ratings (core criteria are in bold text; new criteria are highlighted in green). Proposed criteria New Car Damage Car Rescue Cover New Car Period Car Rescue cover basis New Car Mileage Limit Accident - Transport Windscreen Limit Accident Transport Location Windscreen Limit Non-Approved Repairer Alternative Transport Costs ( ) Audio Limit Manufacturer Driver Under 21 Excess Sat. Nav. Limit - Manufacturer Driver Excess Personal Belongings Windscreen Excess - Repair Car Seat Claims Basis Windscreen Excess - Replacement Loss of Keys Courtesy Car Theft of Keys Class of Courtesy Car Maximum Hotel Expenses Courtesy Car Period Year 1 Cancellation Courtesy Car Guarantee Year 2 Cancellation Enhanced Courtesy Car NCD Protected Claims Total loss courtesy car Guaranteed NCD Total loss car period Uninsured Driver Benefit Repairs Guarantee Vandalism Promise Repairs Guar - Period Annual Foreign Use Limit ULR Limit Emergency Helpline Breakdown Cover (Availability) Legal Advice Helpline The table below sets out the 2014 criteria that we are planning to remove for Criteria planned for removal Loss of Keys Cover ULR Cover Theft of Keys Cover Breakdown Cover (UK) Inexperienced Driver Excess Breakdown Cover (UK) 8

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