2015 Star Ratings. Income Protection. Discussion paper

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1 2015 Star Ratings Income Protection 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 1 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 Income Protection 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 According to Swiss Re s Term & Health Watch 2014, individual income protection insurance sales suffered the greatest downturn in 2013 of all the main protection products. Sales volumes were down 24.4% on the previous year. While most commentators largely agree that income protection is the most important protection product, which the majority of clients typically need, it continues to face significant challenges. Long term income protection, deemed too complicated to be sold direct to consumers, also represents a less attractive option to customers when compared with the lump sum benefits that critical illness policies can potentially pay out. Advisers find the product more difficult to explain and arrange for clients, citing more complicated underwriting and dissatisfaction with financial underwriting arrangements as some of the key detractors. Compared with critical illness cover, there have been fewer product developments over the last year, which together with poor sales underlines the lack of commitment to the product from the provider community as well as the distributors. Mortgage Market Review will challenge income protection sales over the next 12 months Controversy surrounds the publication of IP claims statistics Opportunities exist coming from the HMT simple products initiative and the Seven Families initiative Legislation and regulation Mortgage Market Review (MMR) While income protection insurance is applicable for all clients whether or not they have mortgage commitments, when people take on a mortgage is an ideal time to arrange cover as they consider how they would continue to service the debt in the event of being unable to work due to long term incapacity. The MMR set out the case for reforming the mortgage market to ensure it is sustainable and works better for consumers. In essence, its provisions which came into effect in April are designed to prevent people borrowing more than they can pay back. Whilst this is desirable, there are two implications for protection sales. First, the greater scrutiny of applicants means a more time-consuming process for advisers and there may therefore be less time to consider the client s protection needs. Second, a more rigorous assessment of affordability, taking into account insurance outgoings, may mean people with protection insurances will not pass the affordability test. Under the Mortgage Code, the FSA and now FCA have always required that an adviser ensures their client is at the least aware of the benefits of income protection. It is arguable that advisers fail to meet the MMR regulatory requirement if they allow their client to continue without any form of income protection where it s needed. ABI Claims Statistics In December the claims paid statistics for income protection for the industry as a whole were published for the first time. The industry has a good story to tell with critical illness claims statistics, which are now 3

4 typically over 90%, and it is anticipated that a similar exercise for income protection would also help to address negative publicity about protection insurance and the myth that it doesn t pay out. While this is a laudable exercise by the ABI, there is concern about the voracity of the approach, with a number of providers openly questioning the basis on which the figures have been supplied. This lack of confidence undermines the initiative and has resulted in some providers declining to take part. According to the ABI, 86% of IP claims are paid, but many providers, including friendly societies, report figures above 90%. Restoring the reputation of the insurance industry remains an imperative however and it is everyone s best interests to resolve this issue. HMT Simple Products Initiative In December 2010, a consultation set out the government s initial suggestions for how a range of simple products could be developed. The aims for simple products are: To help consumers benchmark and compare products on the market To be understandable and accessible to the mass market Not to be tailored to meet individual needs, but provide consumers with confidence that a simple product will meet their basic needs and offer them a fair deal To be a viable commercial proposition for providers Templates for simple savings accounts and a simple term assurance product have been agreed and, despite failure to agree a blueprint for a simple income replacement product in the first round, the committee has revisited this important area during the course of the last year. It is now agreed that the issue of income replacement within the simple products initiative should be addressed via the employer group scheme route and proposals are in place for a simple group income protection scheme. In our view, however, there remains an opportunity for providers and distributors in the individual protection market. Apart from the accredited simple products, which will compete primarily on price and service, there is an appetite for providers to market simpler products direct to consumers via strategic partners and using digital marketing techniques. These may not conform to the simple products accreditation standard but nevertheless will be simpler product offerings designed with specific customer groups in mind. Income Protection Taskforce (IPTF) The IPTF continues its work in promoting the product within the industry and beyond. Building on its practical roadshow work with adviser firms where they are provided with training on selling income protection insurance, more recently the interactive Signposts for Income Protection sets out an action plan for the industry. This year sees the launch of the Family Support Initiative, which seeks to demonstrate in a practical and public way the benefits of income protection insurance to those who cannot work due to incapacity. Funding is being promised from sponsoring insurers and the scheme aims to provide seven families with a regular monthly benefit. Their stories and progress will be the subject of a television media campaign. The IPTF is also working on a code of conduct to improve standards and reassure the public. Its work on meanstesting of state incapacity benefits has provided a simple set of questions that advisers can use to ensure their clients, particularly poorer ones, will be genuinely better off with IP when taking into account state benefits. 4

5 All these initiatives will help to create awareness of income protection insurance and people s financial vulnerability if they can t work and hopefully create greater demand for the product. Providers There are 28 providers of income protection insurance contained in our IP table and nearly half of these are life assurance companies offering one or more long term income protection products. The table also contains some friendly societies and provident societies offering their unique Holloway style products as an alternative to or in addition to traditional income protection insurance. 17% of providers are banks and building societies, which largely sell as their own or white-label the products of mainstream insurers. Products/propositions There are currently 28 providers offering some form of long term income protection insurance through 52 different products including three specifically designed for business protection purposes. Almost a fifth is Holloway plans and the remaining four fifths are traditional income protection plans offered either as a standalone plan or as part of a menu proposition. 5

6 Unlike critical illness, for example, where almost all the main brands have enhanced their offerings over the past year, income protection insurance continues to be the poor relation of protection products despite it being the most important cover to have; and this is reflected in the relatively few product developments. There have been new launches: Unum s group sick pay scheme and LV= s Personal Sick Pay. There were four product withdrawals and just six enhancements to existing products. There is an increased focus on own occupation, with a number of insurers amending their contracts to offer terms to more occupations on an own occupation basis. This has no doubt been driven by the bad publicity relating to ADL contracts last year. The traditional long term product delivers the best cover but is more complex for advisers to deal with. It faces challenges from the short term general insurance products and poor distribution although, as discussed above, the HMT Simple Products initiative and the activities of the Income Protection Task could have a positive effect. Additionally, there is speculation that DWP is considering auto-enrolment to IP. 6

7 Key implications for the 2015 Ratings process No changes are proposed to the database or the Star Rating criteria as a result of these developments this year. In addition to the income protection benefits that can be insured by each plan, the Rating takes into account features relating to the flexibility of the contract both in terms of the options available at the acquisition stage and those that enable the plan to accommodate changes in client circumstances. Finally, credit is given for ancillary benefits which provide ongoing help and support to clients, whether or not they need to claim. The following tables set out the criteria for income protection insurance arranged thematically demonstrating the weighting between the various criteria types. 4 and 5 Star rated products will necessarily have to score DNA points in each of these sections in order to achieve the aggregated score high enough to exceed the 4 and 5 Star benchmark. Additionally, certain core criteria are in place where a particular feature or benefit is mandatory for a 4r or 5 Star Rating. Features relating to the acquisitions process (14% of criteria) Underwriting Process POS Decision Given Discount for Exclusions Financial Underwriting Core Criterion for 5 Star Guaranteed Premium Rates Core Criterion for 5 Star Reviewable Premium Rates Features matching benefits to needs (27% of criteria) Termination Age Limited Benefit Term Benefit Amount Index Link Add Indexation No. of Indexation Refusal Indexation Costing Basis Deferred Period 1 Day Deferred Period Two Deferred Periods Own Occ. Throughout Claim Core Criterion for 4 and 5 Star Occupation Definitions Annual Statement Issued 7

8 Features to help cope with changing circumstances (30% of criteria) Option to Increase/Decrease Deferred Period Option to Increase/Decrease Term Option to Increase/Decrease Benefit GIO Set Intervals GIO - Max Age Mortgage/Loan Max Increase Promotion/Salary Max Increase WOP Deferred as IPI Core Career Break Houseperson Maximum Benefit Carers Benefit Relapse Period Hospitalisation Benefit Features relating to income protection benefits (19% of criteria) Effective Maximum % for 25k Effective Maximum % for 50k P11D Benefits Included Dividend Income Included State Benefits Deducted Cont Income Deducted Other Insurance Deducted Pension Income Deducted Non-insured benefits (5% of criteria) Health and Wellbeing Services Claims Support Services Features relating to claims (5% of criteria) Claims Stats Published Number of Exclusions 8

9 Areas for discussion Based on the material in the preceding sections, the following will form the basis of our discussion at the forthcoming round table event. Are the current criteria still relevant to the product and the Star Rating? Specifically, is there a case for stripping out criteria that relate to the proposition to advisers and retain just those that are relevant to the end consumer? Are there any features and benefits of income protection insurance, which are not currently covered within the existing criteria set, that should form part of it going forward? Specifically, is there a case for making the Ratings more focussed on the customer journey with measures for efficiency in dealing with product changes and efficient handling of claims in addition to the ease of acquisition, which is covered to a certain extent by some existing criteria? Is there a case for considering various sub-sets of long term income protection separately for Star Rating purposes, for example, treating friendly society plans differently? What are the prospects for IP in the direct to consumer market? Is it expected that IP sales will increase on the back of the HMT Simple Products Review? With the move to Own Occupation policies, what are the prospects for people in risky occupations? Will a balance between IP and STIP be achieved and what will define those two markets? 9

10 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). Proposed criteria Income Protection Insurance Underwriting Process Employed House Person Maximum Benefit POS Decision Given Carers Benefit Premium Discounted when Elements of Cover Excluded Relapse Period Financial Underwriting Hospitalisation Benefit Annual Statement Issued Effective Maximum % for 25k Termination Age Effective Maximum % for 50k Limited Benefit Term P11D Benefits Included Option to Increase or Decrease Deferred Period Dividend Income Included Option to Increase or Decrease Term State Benefits Deducted Option to Increase or Decrease Benefit Continuing Income Deducted GIO Set Intervals Other Insurance Deducted GIO Maximum Age Pension Income Deducted Mortgage/Loan Maximum Increase Own Occupation Throughout Claim Promotion/Salary Maximum Increase Deferred Period Indexation 1 Day Deferred Period Additional Indexation Two Deferred Periods Number of Indexation Refusals Range of Occupation Definitions Coverage Indexation Costing Basis Claims Support Services Included WOP deferred as IPI Health & Wellbeing Services Included Guaranteed Premium Rates Claims Stats Published Reviewable Premium Rates Number of Exclusions Career Break 10

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