Housing Regulation in Victoria: Building Better Outcomes

Transcription

1 A response to the Victorian Competition and Efficiency Commission s Draft Report Housing Regulation in Victoria: Building Better Outcomes Response from Warranty Division of Vero Insurance Limited Dated: 31 August 2005 For further information contact: Paul Jameson General Manager Vero Warranty Division Phone: (02) Mobile: paul_jameson@vero.com.au

2 Table of Contents 1 Preamble Vero Comments Quotes based upon vexatious comments Requests for Further Information Draft Findings Draft Recommendations Clarifications, errors and omissions Cost of Warranty Insurance Bank Guarantees $10,000,000 Cap Vero Product Range and Service Comments by the Builders Collective Other insights or comments Was there really a BWI crisis? Consumer information disadvantage Competition in the Victorian BWI market Building Advice and Conciliation Victoria Inspection processes Chiwest case study Response from Vero Warranty Page 2 of 24

3 1 Preamble 1.1 Vero Comments The Inquiry s draft report is extensive in reach and coverage. The Vero response will be limited to issues and points of discussion about which we have an informed view and where we believe we can make a worthwhile contribution to the debate. The absence of a Vero response to a particular finding or recommendation should be interpreted as: We neither agree nor disagree. This would generally indicate that: We have no direct or indirect involvement with the matter, or We have nothing material to add. 1.2 Quotes based upon vexatious comments The draft report includes several quotations from the Builders Collective of Australia Inc about Vero Insurance Ltd and, specifically, allegations about our builders warranty insurance practices. The statements themselves (referred to in detail in the body of our response) are misleading, factually incorrect and/or defamatory. 2 Response from Vero Warranty Page 3 of 24

4 2 Requests for Further Information (1) Pg Different impacts of local government regulatory requirements Inappropriate application of local governments planning approval processes has high impact potential in terms of both extra costs and time demands. Such action tends to undermine consistency with the national building code. While this is a larger, national problem, it remains an issue that Victoria should monitor closely. Local governments are not always effective gatekeepers for Builders Warranty Insurance (BWI). For example, there is patchy checking for valid BWI at the time of issue of the building permit. (2) Pg Advantages and disadvantages of defining exemptions on the basis of the type of building rather than monetary value. No comment except to draw the Commission s attention to the definitional difficulty associated with BWI if non-monetary is used, i.e. this is the reason why the monetary threshold has remained despite being revisited regularly across many jurisdictions. (3) Pg Impediments to alignment of thresholds From Vero s point of view there are no impediments and we foresee no negative issues. We would support such an alignment in the interests of national consistency and to reduce the level of regulatory complexity. (4) Pg Frequency with which councils are required to address matters approved by a private surveyor No comment other than refer the Commission to Section 6.5 of this response concerning our view of the current inspection process. (5) Pg Benefits and costs of mandatory plumbing insurance for building construction If the value of the work exceeds the threshold ($12,000) then logic dictates that, plumbing work being no different to other kinds of construction activity, the warranty insurance requirement must be identical in cover and both either o o Mandatory (which we favour), or Voluntary. Response from Vero Warranty Page 4 of 24

5 The PIC scheme consists of one broker (Marsh) and one insurer (QBE). We see no realistic alternative to this natural monopoly given that the premium pool is so small (probably not more than $5 million). Where the plumbing work is sub-contracted, the prime contractor should be solely responsible for the warranty insurance, avoiding unnecessary overlap. Providing only one class of builders warranty insurance, irrespective of the contractor s trade, appears undeniably logical. After all, this is the situation applying in other jurisdictions. (6) Pg Benefits and costs of mandatory plumbing insurance for air conditioning and mechanical services Please see above comments. (7) Pg Influence that insurance arrangements might have on the propensity of insured practitioners to pursue innovative performance-based solutions to meet building standards. It is possible that a particular insurer may take an overly conservative stance with regard to innovative building practices but, given the degree of competitiveness in the Victorian market, it would not be in an insurer s best interest to be too conservative. Smart insurers will look positively at new practices that have passed the appropriate technical scrutiny. An innovative builder should be able to find a supportive insurer and would not be disadvantaged so long as his work met the technical standards. The issue becomes one of ensuring that the Building Code of Australia and local government planning regulations keep pace with relevant building innovations. Home warranty insurers exist partly to take the innovation risk away from home owners and to ensure their builder customers apply effective risk management. (8) Pg Cost or practicality of requiring eligibility criteria for providers of professional indemnity insurance Professional Indemnity insurance should be provided only by APRA approved and regulated insurers. Response from Vero Warranty Page 5 of 24

6 Unlike BWI, we do not see that it is necessary to pre-approve the insurer unless it becomes a compulsory class (as distinct from a mandated policy). Although not a compulsory class, the insurance cover is still purchased to protect the consumer interest, primarily where the home owner is contracting directly with the professional. There seems little point to pre-approving insurers if the regulatory body, including if APRA, does not have the power to issue directions to a rogue insurer and/or the ability to sequester funds, if and when it becomes necessary. This can t be done unless they re directly regulated by APRA; while ASIC has similarly limited reach, especially in relation to direct offshore foreign insurers. (9) Pg Costs and benefits of merging registration and licensing functions of the Building Commission and Plumbing Industry Commission From an insurance perspective this would be a positive move because: It would provide tighter oversight. There would be less overlap between the plumbing entity and the building entity. In NSW, where there has never been a separation, there is no problem. It is still possible to focus upon the plumbing aspects, when necessary. The benefits of a merger include: Overcoming the problem of Building and Plumbing regulation overlap, and worse, contradiction. Avoiding the complication of sorting out which insurer responded to a claim, i.e. the building warranty or plumbing warranty in cases of claims involving water or sewerage reticulation. Taking the best from each set of regulations would result in a better scheme for all. Merger costs would be one-off, relating to the work associated with the alignment of the regulations, while the benefits would be on-going. (10) Pg Costs of complying with selected regulations. No comment. Response from Vero Warranty Page 6 of 24

7 3 Draft Findings 5.3 Building Codes Australia We provide as an attachment, Vero s reply to the Productivity Commission Report into Reform of Building Regulation and draw your attention to those recommendations where we feel there is an opportunity to achieve more, namely: Documentation of maintenance requirements. The removal of unnecessary overlap between the BCA and the Plumbing Code. Broader property protection requirements with respect to fire. The erosion of national consistency by local government planning processes. Maintaining national consistency as no less important than compliance and enforcement matters. Refer your Draft Recommendation Access to BCA on-line should be tied into continuing professional development. We support the HIA concept of a statutory government body to replace the ABCB and bind the States and Territories to a nationally consistent building code. All future regulatory changes to the BCA must be fully justified. The April 2005 developments introduced by the Federal Government in agreement with the States and Territories are welcomed but will require close monitoring. We would welcome the opportunity for insurance industry representation on the Board. As the BCA is amended every 12 months by the Building Codes Committee of the ABCB, we suggest that proposed amendments are communicated to BWI insurers in time for them to: Provide feedback Make the necessary adjustments to their risk assessment processes and underwriting guidelines. Response from Vero Warranty Page 7 of 24

8 7.1 Mandatory BWI appears justified in view of the intractable information asymmetries facing consumers We agree with the finding. Please also see our comments under section 6.2. later in this Response. 7.2 Change to last resort We agree with the finding but do strongly urge that the phrases first resort and last resort be dropped from the debate as they are misleading in the extreme and tend to be associated with overly emotive reactions. The alternative would be a clear definition of each term accompanied by a reiteration that defects remain covered, along with noncompletion/loss of deposits, subject to the death, insolvency and disappearance triggers for certificates issued from 1 July It should also be borne in mind that, ultimately, one of these triggers will still occur if the builder does not meet their obligations. 7.3 Multi-storey dwelling exemption is appropriate While we agree with this finding we nevertheless feel strongly that something more must be done to protect the buyers of multi-storey units and apartments. Until there is tighter regulation during construction, some developers will continue to take short cuts and transfer an inappropriate proportion of the maintenance risk to the consumer. It is because the risk is so difficult to quantify in aggregate and assess by individual builder that the insurance industry finds it unacceptable in the context of BWI. We advocate fixing the problem rather than transferring it. This would entail some political risk associated with developers. But we believe a better framework is achievable, particularly if a BWI-style backstop defect risk protection for the body corporate is achieved by mandating their cut-through to the performance guarantee provided by the builder to the developer (accompanied by a minimum 3 year defects period). 7.4 Architects and engineers We support the finding. 7.5 Government monopoly provider would not deliver superior outcomes We support the finding. Response from Vero Warranty Page 8 of 24

9 7.6 Mandatory BWI cost relative to voluntary BWI cost We support the finding indeed we believe that the cost of voluntary BWI would be higher due to a lack of scale and because it is reasonable to assume a high level of negative selection. 7.8 Mandatory owner-builders warranty insurance appears justified We agree. Response from Vero Warranty Page 9 of 24

10 4 Draft Recommendations 5.4 Water saving regulation in the 5 Star scheme We support the recommendation but draw the Inquiry s attention to the issue of possible emerging risks. Due to the development of new technologies, there is always the potential for the response to environmental issues to develop into newly emerged insurance risks and, subsequently, claims. The recommendation should include an element of consultation with the insurance industry to ensure a measured introduction. Communication and awareness supports early intervention; preventing potential problems escalating. 6.1 Installation of metal roofing not confined to plumbers We support the recommendation on the basis that it would help to reduce BWI overlap and hence eliminate some duplication of costs. 6.3 Part-time registration. We support the recommendation. Furthermore, we see the need for a sub-category of builders, namely inactive unlimited builders, such that they would not need to maintain BWI eligibility during a period of inactivity. This would be positive for the inactive builders and neutral for all other parties including the insurance industry. 6.4 Monitor and report on the impacts of the new owner-builder regulations We support the concept of owner-builders being more aware of the implications of their role but agree with the Commission that there are no guarantees that this will be sufficient to rectify the problem of excessive use of the category. We feel that the current measures do not go far enough and, on their own, will not be adequate to prevent future difficulties. Some builders will still be able to talk some owners into becoming owner-builders on the basis of reducing fees and BWI costs for the sole purpose of avoiding their legal responsibilities. Response from Vero Warranty Page 10 of 24

11 The only permanent solution to this seemingly intractable problem is that all owner-builders, in addition to being subject to the same fee structure as builders, take BWI at the commencement of building - not just if and when they sell the property within the warranty period. This will not adversely impact the genuine owner-builder. The incremental cost will not be significant as the genuine owner-builder segment could be priced based on their community performance. Indeed, we believe such an approach will: Restore the standing of the committed, technically competent, home building and trade professionals who build their own homes. Deter others who attempt to work under the radar of the broader regulatory framework. 7.1 Documentation re BWI provided at the start of the job We agree that this is sensible and see no impediment. However, while the purpose of the documentation is to inform home owners of their rights, more information could lead to more claims that, in turn, could flow through to higher premiums. 9.4 Building Commission budget approval process and annual reporting We agree. 9.5 Information to consumers about their rights We strongly agree with this. Our survey research of claimants, supports the proposition. In fact, respondents have indicated, by a significant majority, that they would appreciate some more meaningful way of comparing builders technical capability and financial soundness for themselves Performance of BC and PIC against aims and objectives We support this initiative. 11.1The BACV levy should only apply to residential building activity Agreed. But there is room for the dispute resolution service to be more efficient. Then, as costs reduce, the total levy could also reduce. Registration of Companies We support the registration of companies provided it does not lead to de-licensed builders returning under a different guise ( phoenix ). In Response from Vero Warranty Page 11 of 24

12 NSW, the Home Building Amendment Act, 2004 gave the Home Building Services (HBS) broad powers to prevent this. Response from Vero Warranty Page 12 of 24

13 Clarifications, errors and omissions 4.1 Cost of Warranty Insurance Pages 22 and 364 Table C.2 If it is true that total compliance costs represent between 4% and 20% of the value of a house then we can but conclude that there are many more pressing problems than warranty insurance, because the insurance cost is only a fraction of this amount. See for more details Page 23 A simple range, with some data drawn from anecdotal reports, to describe the cost of warranty insurance is not particularly helpful and can be misleading. For example, at the bottom end of the listed range, 0.5 per cent of contract value represents Vero s average premium for our 2004 average insured contract value. By definition, this is not the bottom end of our range and therefore cannot be the bottom end of the industry range. (Presumably it was the lowest figure quoted by any submission to the Inquiry?) Vero s average premium is representative of a very large proportion of the market. What market share is represented by the values, for example, at the top end of the listed range? If it is not roughly equal to Vero (and it cannot be) then the range is misleading. A far more valuable representation of the true cost position would be given by a frequency distribution table which would demonstrate the proportion of the market represented by each contract value band. The vast majority of Vero policies withinn Victoria cost under $1500.We note that you have requested those who provided these anecdotal estimates now provide more detailed submissions. However, as this request was not made all that obvious, it would appear unlikely you ll receive a representative, statistically relevant, sample Page 154 You comment the pervasive influence of warranty insurance and the significant economic and personal costs recently associated with it. Without evidence to support this assertion, the statement is unsubstantiated and quite emotive. Response from Vero Warranty Page 13 of 24

14 We would suggest that the Commission either: Provides quantitative evidence in support of this comment, Alters the wording of the statement, or Removes it completely in the interest of balance Page The reference to the ACCC in relation to Vero is misleading. The associations contained therein are not factual and have the potential to be defamatory. 2. Vero s Victorian average contract value is not $250,000. The above figure is vastly higher than that supplied in the original submission of 2004 and hence all comparisons based on this figure are incorrect and misleading. The price of a BWI policy is not calculated by a simple linear relationship, depending upon contract value alone. Therefore to take Vero s average rate, based on average contract value, and apply it to higher contract values is mathematically incorrect and distorts the position. Since 2004, Vero s Victoria average premium to average contract value has continued to reduce further. The average premium for the 6 months to June 2005 was $735 and the Page 164 Referring to the administration costs for builders, you quote an example from McCormick Builders and Property Power. Would it not be more accurate, and of greater assistance to the community, to document what happens in the vast majority of cases rather than use a sample of two? Page 176 Your comparison of Victorian and Queensland average premiums is interesting. If we also take into account the following points, it further highlights the efficiency of the Victorian privatised scheme relative to the Queensland government monopoly. Response from Vero Warranty Page 14 of 24

15 The BACV is not yet fully effective, whereas the QBSA is quite effective in early intervention Page 180 The Commission seems to imply that the mandatory nature of BWI adds an incremental cost relative to insurance not being mandatory. It asks the question If it were not compulsory, what proportion of dwelling construction would have such cover? We would have thought that 2 equally compelling questions would be: What would be the cost to the community of a higher level of builder failure due to a lack of financial scrutiny currently provided by the insurance sector? What would be the cost incurred by a small percentage of home owners, when uninsured builder failures put at risk a large proportion of their life savings? While we concur with your draft finding we find the argument leading to it quite confusing in that it criss-crosses between the impact on the individual and the home building community as a whole. Response from Vero Warranty Page 15 of 24

16 4.1.8 Page 372 Table C.6 From Table C.6 we could conclude that the administration time associated with warranty insurance is not excessive, ranging from 0.5 hours to 4.0 hours per job, costing between $20 and $160 (although we again note the limited, anecdotal, basis for this table). This is the only cost which is not borne directly by the home owner. 4.2 Bank Guarantees Page 165 There are a number of points requiring clarification and correction: Bank guarantees are facility related not contract specific. A bank guarantee, i.e. security, is only required if a builder does not meet the minimum financial tests of soundness, such as holding net assets of 10% of annual turnover. The bank fee is generally 2-3% per annum of the face value of the bank guarantee issued. To use an example. If a builder s turnover is $2million p.a., the bank guarantee is for 10% of turnover or $200,000, and the fee is 2.0% of the security or $4,000. At an average contract value of $160,000, the number of contracts in a year would be approximately 12.5 and the cost of the bank facility, spread across these contracts, would be $320 each. Set against the opportunity cost of tying up $200,000 in net assets, the price is not onerous. It is often the reason why builders choose to use securities. 4.3 $10,000,000 Cap Page 156 In the context of consumer concerns, your dot point 3 says A $10,000,000 cap was introduced for claims against a single builder. This is not correct, there is no cap as far as the consumer is concerned. At the time of the 2002 reforms, the primary insurance market found it impossible to secure the necessary reinsurance arrangements for aggregate builder claims above $10 million. The respective state governments agreed to step in and act as the reinsurers. Response from Vero Warranty Page 16 of 24

17 The reinsurance arrangement with Victorian Treasury works like any other commercial reinsurance treaty. It applies to an aggregate claim above $10m for any one builder or builder group. If the $10m threshold is breached, the insurer continues paying the claim(s) and then seeks recovery from the reinsurer (i.e. Treasury). There is NO negative impact upon the consumer (protection) OR artificial tilting of the building industry s competitive landscape in favour of the bigger builders. 4.4 Vero Product Range and Service Page 37 A potential consequence of tightening the requirements for entry to a building profession, for example, is that it becomes harder for new suppliers to enter. BWI does not prevent new suppliers entering the building profession. Since 2003 Vero have offered a product that is available to new builders entering the market. We have paved the way for many first time builders in Victoria to enter the market. The annual turnover limit and the contract limit for single dwellingsare more than sufficient for genuine new entrants. Effectively, new builders need just their vehicle and tools then they can prove themselves with the first one or two homes they construct. After a short period of time new builders often become eligible to step up to a mainstream BWI product. While we understand the context, we would appreciate you weaving into the theoretical discussion that insurers like Vero have recognised the problem and make every attempt to accommodate the genuine, committed builder, no matter their position on the time in industry continuum. Response from Vero Warranty Page 17 of 24

18 4.4.2 Page 167 Today consumers claims on their extant builders do not go through an insurer. In principle this may be correct but the practice is generally quite different. Home owners still phone their insurer with a builder complaint, in the first instance. At Vero because the call highlights a contingent risk, we still manage the complaint, up front often in conjunction with the regulator. Early intervention works to minimise the cost and distress of disputes and claims for both builder and home owner. If the issue is minor in nature, we encourage the consumer to sort it out directly with their builder. On-site mediation services (such as those provided by the NSW HBS) are a valuable addition to the first response package Page 183 The Vero product mentioned by Port Phillip Constructions has been available for almost 2 years, having been introduced in September At that time a large majority of builders who had been with Vero for the qualifying period, were automatically converted to the new product. 4.5 Comments by the Builders Collective Pages 163 and 179 monopoly power Some inquiry participants, such as the Builders Collective of Australia, claimed the premium increases were the exercise of virtual monopoly power by the largest insurer remaining in the market following the collapse of HIH. The Builders Collective claims are false, misleading and deceptive. In our view, it is totally inappropriate for the Commission to refer to false statements in its report. Furthermore, the reference mentions participants in plural. Response from Vero Warranty Page 18 of 24

19 Given that false assertions should not appear, it follows that false statements certainly cannot be allowed to appear anonymously. Therefore, could you please supply further details of the other party/ies making this assertion so that we can provide you with the appropriate verification? Vero s market share in Victoria, even following the collapse of HIH, has never exceeded 80%. There has always been at least one other insurer in the market, Australian Home Warranty/Reward Insurance being that second insurer. Vero and Reward (whose portfolio is now absorbed into Australian International Insurance Ltd) were the only insurers with the expertise and the risk appetite to take on such an insurance challenge during very difficult times. We neither sought nor preferred a duopoly market and our price increases during the period were presented to the ACCC before implementation. No objection was ever raised. While the ACCC never says so, we believe it was quite clear to them that the price changes were necessary to meet the developing claims and provide the appropriate margin Page 163 ACCC investigation and the timing of broader distribution Vero spread its distribution to the Master Builders Association (MBA Insurance Services Pty Ltd) and other brokers (now some 50 in total) on 1 July 2002, well before the ACCC investigation into alleged breaches of the Trade Practices Act. In May 2004, the ACCC found that (and we quote directly from the letter sent to the complainant, the Builders Collective) the conduct about which you complained concerning your dealings with Vero does not appear to breach the Trade Practices Act and the Commission will not be taking further action in relation to your complaint. Response from Vero Warranty Page 19 of 24

20 The Builders Collective allegations are false. It is factually incorrect to state or imply that Vero s action in offering its product to the MBA was subsequent to and influenced by the ACCC investigation Page 185 You quote Tyler from the Builders Collective submission. HWI makes it difficult for a qualified, ambitious young builder with limited capital to enter the industry Please refer to our comments under and note that this product was introduced in 2003, well before the Tyler quote of It should also be noted that the Tyler report was commissioned by the MBA, NSW, subsequent to the release of the Grellman Inquiry Report. We would strongly suggest that, if not done already, VCEC review that report (and the terms of commission) if you intend to keep any references in the final report. NB: A close examination of the material referred to by those who take issue with the BWI scheme will show that there is a high degree of repetition of the same, unbalanced and misleading facts in support of their arguments. Response from Vero Warranty Page 20 of 24

21 5 Other insights or comments 5.1 Was there really a BWI crisis? Please refer to Page 126 and Table 6.1 Building Practioners Board registrations which indicates During the 2 years between 2001/02 and 2003/04, domestic builder unlimited numbers in Victoria decreased by 5%. Some transferred into the domestic builder limited category and the net reduction was therefore somewhere between 3% and 5%. During the same period, engineers decreased by 3%, commercial builders decreased by 3% and building inspectors decreased by 3%. In the domestic builders unlimited category, it is difficult to detect any significant factors overlaying what appears to be normal industry consolidation of 3%. Where is the hard evidence for a crisis that drove hundreds of builders out of the industry? 5.2 Consumer information disadvantage In section you analyse the housing construction market and its consumer information disadvantage compared to other similar markets. We agree with your basic conclusions that: There is a clear need for consumer protection through mandatory BWI. The degree of disadvantage is not sufficient to justify government intervention to the extent of taking over BWI. On the other hand, more needs to be done to address some elements of the issue, particularly to minimise the disadvantage in critical areas. We know that 2 common assumptions often made by consumers have the potential to lead to later difficulties, namely: All builders do not provide a quality of construction that is equal to the average, and It does not necessarily follow that, when a builder abides by the Building Code, a consumer will be satisfied with the result. Response from Vero Warranty Page 21 of 24

22 Vero suggests that the consumer needs to be provided with more information up front, such as: An explanation of BWI insurance and what it covers and does not cover. Information about the proposed builder; his past experience, quality of prior work, financial security, etc. On this latter point, it has been proposed that the category rating assigned to builder by his home warranty insurer may serve as a proxy source of this information. We do not believe this would be workable for the following reasons: Insurers do not use a uniform methodology for categorising builders The insurance rating category is complex and could not easily be communicated to the consumer Such a move would put the insurer in a difficult position. If this were to be pursued, we would advocate looking at a system of builder endorsement that is provided commercially by an independent party (with input from insurers). 5.3 Competition in the Victorian BWI market Page 159 The Australian market and, hence, the Victorian market, is not only different from overseas (on the grounds of its cultural and institutional framework), it is also operating under entirely different economic dynamics. Compared to American or European markets, the Australian residential construction sector is small and, indeed, can still be characterised as a cottage industry. A voluntary system would inevitably reduce the premium pool to subscale levels Page 179 QBE have only just entered the Victorian market (August 2005). The draft report omitted the most recent newcomer, Calliden (who is underwriting the Building Ethics product). Response from Vero Warranty Page 22 of 24

23 5.3.3 Page 181 We do not believe that it is accurate to quote The inability of many, small, specialist and older builders to obtain adequate warranty insurance for their business needs has seen many exit the domestic building industry. Please refer to 6.1 above for a comment on builder numbers. Secondly, there are now available in the Victorian market many alternative insurance models, catering to the full cross-section of builder operators, including those who do not fit a mainstream profile. 5.4 Building Advice and Conciliation Victoria We believe that the BACV is not working well for the following reasons: It is voluntary and non-binding The BACV cannot enforce its directions The party which does not agree with the decision inevitably escalates the dispute to VCAT This is a double handling and involves additional legal costs, entrenches the positions of each party and delays resolution The result is a significant increase in time, cost and frustration levels Also, the BACV do not have a good working understanding of the BWI legislation, continually referring complaints to the insurer when the builder remains solvent and trading. It can be no surprise that consumers are confused by the situation. Response from Vero Warranty Page 23 of 24

24 5.5 Inspection processes There are insufficient mandatory building inspections and so there follows: Too great a potential for defective and/or non-compliant work going undetected between frame and completion No requirement for an inspection and approval of waterproofing (an element in the majority of claims). There is a lack of control of, and accountability by, building surveyors and inspectors: Poor record keeping No quality control No statutory requirement to co-operate with investigations into reports of defective and/or non-compliant work. Finally, surveyors and inspectors often fail to use (or use responsibly) the legislative powers that are available to them. 5.6 Chiwest case study In the interests of a balanced report, we trust that, if you do receive this and other case studies from the Builders Collective, you will contact us to provide a response (as originally developed when these first came to light). It will also be relevant for you to be updated with developments since especially in relation to Chiwest. Response from Vero Warranty Page 24 of 24