Conduct of Business Returns ( CBR s ) Revised Categorisation, questions and reporting levels Response to industry comments

Transcription

1 Conduct of Business Returns ( CBR s ) Revised Categorisation, questions and reporting levels Response to industry comments EECUTIVE SUMMARY This document provides a guide to the revised draft Conduct of Business Returns ( CBR s ) released for public comment, following consideration of comments received on the previous draft and alignment with the proposed prudential regulatory reporting requirements in terms of the future Solvency Assessment and Management ( SAM ) framework. The CBR s are a new set of market conduct returns that will need to be completed by all life and non-life insurers in South Africa, excluding reinsurers and captive insurers 1. The CBR s will form part of the off-site supervision framework for insurers, with the aim of providing the Financial Services Board ( FSB ) with a quantitative summary of key market conduct risk indicators. The market conduct risk indicators have been informed by various data sources, such as on-site visits, complaints information and local and international policy and regulatory developments. These indicators will be reviewed on an annual basis to ensure that they remain relevant. The CBR s will feed into the overall market conduct risk-based supervision framework, which contemplates the development of conduct risk profiles for individual insurers and groups. The first version of the draft CBR s was sent out to industry associations for comments on 31 October The CBR s have been significantly revised subsequent to the consideration of comments received from various stakeholders and industry consultation workshops held with the South African Insurance Association ( SAIA ), the Association for Savings and Investment South Africa ( ASISA ) and other industry representatives. The reporting classes of the CBR s have also been aligned, as far as reasonably possible, to the reporting classes contained in the SAM draft reporting templates and the classes and sub-classes of insurance business set out in Schedule 2 of the Insurance Bill, Although largely aligned, there will be some differences between the granularity of reporting information required for purposes of prudential supervision and market conduct supervision respectively, due to the different supervisory objectives sought to be achieved in each case. In order to monitor key conduct outcomes, the reporting classes are broken down into more granular benefit or cover types for the purposes of the CBR s. 1 A captive insurer refers to an insurer that only insures first party risks. First party risks in respect of a captive insurer means the operational risks of (i) the group of companies of which the insurer is a part; (ii) any associate of a company that is part of the group of companies referred to in (i); or (iii) any joint arrangement that a company that is part of the group of companies referred to in paragraph (i) participates in. Page 1 of 55

2 The updated draft CBR s consist of a number of sheets depending on the number of classes of business underwritten by a specific insurer. For each sheet, the columns reflect the benefit or cover types per class of business. The breakdown of these benefits or cover types per class of business are provided in section 4 below. Each return also contains sheets containing instructions on how to complete the returns, an explanation of terminology used, a declaration that must be signed on behalf of the insurer and a general sheet. The general sheet contains questions relating to remuneration for outsourced activities, advertising and marketing expenditure and complaints management. An additional section has been added with questions relating to add-on or rider benefits. Below is a brief explanation of the rationale behind the information requested in each section of the CBR s: 1. Business Composition This section focuses on identifying trends in the sales, lapses, not taken up s and cancellation of policies depending on the different distribution channels of the insurer. It will provide information regarding possible mis-selling, growth in different channels of business, movement of policies in the industry and the chosen distribution channel for different target markets. 2. Distribution and Binder Costs Statistics on commission payments will enable the monitoring of regulatory caps and provide an indicator of the size of each distribution channel used by an insurer. Statistics on the binder and other fees paid, such as aggregation fees, will provide valuable information regarding the reliance placed on third parties and the total expenditure in each instance. 3. Claims Management This section requests information on the number and value of claims submitted, as well as the number of repudiated and outstanding claims, to enable the monitoring of an insurer s performance in relation to efficient and fair claims handling. 4. Complaints Handling Reporting on complaints management is split between the main sheets and the general sheet as indicated above. The complaints management information will assist in identifying trends, root causes for complaints and areas for improvement relating to products sold or services rendered to the customer. The categories used are aligned with the categories identified as part of the TCF complaints management framework as published in the Discussion Document on Consumer Complaint Management by regulated financial institutions, aligned to the Treating Customers Fairly framework. 5. Add-on/Rider Benefits In order to ensure a complete view of all benefits offered by insurers, it is important to understand the types of ancillary benefits being offered as well as the types of policies to which such benefits are linked. This includes information on bundled and/or combined products. Page 2 of 55

3 The information provided through the CBR s will assist the FSB to identify trends and highlight specific market conduct risks relating to individual insurers as well as the wider industry. It should also provide insurers with important management information to help monitor and manage market conduct risks on an on-going basis. The revised draft CBR s are released for comment. The final version of the CBR s may also be further influenced by changes that may be required due to deliberations on the Insurance Bill, INTRODUCTION, PURPOSE AND SCOPE The purpose of this document is to provide a guide to the revised draft CBR s following consideration of comments received on the previous draft and alignment with proposed SAM reporting templates. The document does not provide detailed feedback on each of the comments received; in most instances the comments have been incorporated into the revised version of the CBR s. This document outlines: the breakdown of the reporting classes; the questions contained in the returns; and an indication of the level of reporting class at which the various questions need to be answered. The above mentioned classes, questions and levels of reporting are set out separately for Life and Non-life insurers in section 4 of the document below. A guide to the terminology used in the returns is attached hereto in two separate documents (for life and for non-life) to serve as supporting documents for the CBR s. 2. REPORTING REQUIREMENTS The final CBR s will be required to be completed electronically and submitted via the Electronic Submission portal on the FSB s website. The CBR s will need to be submitted quarterly, but a two-year phasing-in period will apply during which the reporting period will be bi-annual. All submissions will need to be received via the portal within 60 days after the end of the relevant period. It is accepted that it may not be possible to complete the returns in full or with the adequate level of detail immediately upon implementation. However, the FSB would prefer to accept incomplete returns upfront and monitor progress over time rather than a phased implementation. This will enable the FSB to monitor the progress of individual insurer s with respect to system development, implementation of systems and analysis of data with the submission of each return. Page 3 of 55

4 3. INVITATION TO COMMENT, PROJECT PILOT AND PLANNED IMPLEMENTATION DATE The practical implementation of the CBR s will have three components. Firstly, all life and non-life insurers are invited to comment on the revised categorisation, level of reporting and questions in the CBR s as contained in this document. Comments must be submitted to the FSB c/o FSB.INSCBRComments@FSB.co.za on or before 18 March In addition, the Deputy Registrar will request SAIA and ASISA to submit the names of insurers who wish to participate in a pilot project to test the functionality and practical effectiveness of this version of the CBR s. The testing period will run concurrently with the comment period. Finally, all feedback from the pilot project will be taken into consideration together with the general comments received from the industry to inform possible further amendments. The planned implementation date for the final version of the CBR s is June Page 4 of 55

5 4. REPORTING S FOR CBR S This section sets out the recommended reporting levels for the CBR s, as amended and aligned to the SAM reporting classes as set out in Schedule 2 of the Insurance Bill 2015, but at a more granular level in some cases TABLE: LIFE INSURANCE Levels 1 and 2 are aligned to the classes and sub-classes in the Insurance Bill. Reporting on levels 2, 4 and 5 is required in the instances set out in section 4.2 below, where further information is required on specific cover types and or benefits RISK a. Individual Death Individually risk rated Underwritten on a group basis b. Individual Health Individually risk rated Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency Page 5 of 55

6 evacuation or transport Underwritten on a group basis Non-medical expense cover as a result of hospitalisation c. Individual Disability lump sum Individually risk rated Underwritten on a group basis Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Own occupation disability Own/similar occupation disability Total disability Functional Impairment Own occupation disability Own/similar Page 6 of 55

7 occupation disability Total disability Functional Impairment d. Individual Disability recurring payment Individually risk rated Underwritten on a group basis Own occupation disability Own/similar occupation disability Total disability Functional Impairment Own occupation disability Own/similar occupation disability Total disability Functional Impairment e. Group Death f. Group Health Non-medical expense cover as a result of Page 7 of 55

8 hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport g. Group Disability lump sum Own occupation disability Own/similar occupation disability Total disability Functional Impairment h. Group Disability recurring payment Own occupation disability Own/similar occupation disability Total disability Functional Impairment Page 8 of 55

9 FUND RISK a. Death b. Disability lump sum Own occupation disability Own/similar occupation disability Total disability Functional Impairment c. Disability recurring payment Own occupation disability Own/similar occupation disability Total disability Functional Impairment 3. CREDIT LIFE a. Individually risk rated Mandatory Death; Disability (lump sum); Own occupation disability Own/similar occupation disability Page 9 of 55

10 Total disability Functional Impairment Disability (recurring); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Health (lump sum); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring); Non-medical expense cover as a result of Page 10 of 55

11 Retrenchment Other hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Optional Death; Disability (lump sum); Disability (recurring); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Own occupation disability Own/similar Page 11 of 55

12 occupation disability Total disability Functional Impairment Health (lump sum); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing Page 12 of 55

13 Retrenchment Other and treatment Medical emergency evacuation or transport b. Underwritten on a group basis Mandatory Death; Disability (lump sum); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Disability (recurring); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Page 13 of 55

14 Health (lump sum); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Retrenchment Page 14 of 55

15 Other Optional Death; Disability (lump sum); Disability (recurring); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Own occupation disability Own/similar occupation disability Total disability Functional Impairment Health (lump sum); Non-medical expense cover as a result of hospitalisation Frail care Page 15 of 55

16 HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Retrenchment Other 4. FUNERAL a. Individual Individually risk rated Individual underwritten on a Page 16 of 55

17 b. Group 5. LIFE ANNUITIES a. With Discretionary Participation features b. Other group basis 6. INDIVIDUAL INVESTMENT a. With Discretionary Participation features Fund member policies Retirement annuities Preservation funds Endowment policies Other 7. FUND INVESTMENT a. With Discretionary Participation features b. Other Fund member policies Retirement annuities Endowment policies Other Preservation funds Page 17 of 55

18 b. Other 8. INCOME DRAWDOWN a. With Discretionary Participation features b. Other 9. COMBINED POLICIES a. Universal Life With Discretionary Participation features Death; Disability (lump sum); Own occupation disability Own/similar occupation disability Total disability Functional Impairment Disability (recurring); Own occupation disability Own/similar occupation disability Total disability Page 18 of 55

19 Functional Impairment Health (lump sum); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring); Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Page 19 of 55

20 Other b. Fund Member Policies With Discretionary Participation features Death Disability (lump sum) Own occupation disability Own/similar occupation disability Total disability Functional Impairment Disability (recurring) Own occupation disability Own/similar occupation disability Total disability Functional Impairment Health (lump sum) Non-medical expense cover as a result of hospitalisation Frail care Page 20 of 55

21 HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Health (recurring) Non-medical expense cover as a result of hospitalisation Frail care HIV, Aids, tuberculosis and malaria testing and treatment Medical emergency evacuation or transport Other Page 21 of 55

22 CBR s response to industry comments 4.2 QUESTIONS AND REPORTING FOR LIFE INSURERS LIFE INSURERS 1 BUSINESS COMPOSITION State the number of policies in force at the end of the quarter. State the number of benefits in force at the end of the quarter. State the total gross written premium for all policies in force at the end of the quarter. State the number of new policies issued in the quarter. State the number of new benefits issued in the quarter. OF QUESTIONS State the total gross written premium for all new policies issued in the quarter. State the number of new policies issued in the quarter as per the income group breakdown below: Low income; Middle income; Upper income State the number of new policies issued in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Page 22 of 55

23 LIFE INSURERS OF QUESTIONS Other (please specify) State the gross written premium for new policies issued in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead aggregators; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Page 23 of 55

24 LIFE INSURERS Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); OF QUESTIONS Other (please specify). State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies cancelled on the instruction of the policyholder (excluding cancelled in cooling off period ) during the quarter. State the number of policies cancelled on the instruction of the insurer during the quarter. State the number of policies which were cancelled in terms of cooling off provisions during the quarter State the number of policies less than 12 months old that lapsed in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Page 24 of 55

25 LIFE INSURERS Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); OF QUESTIONS Other (please specify). State the number of policies less than 12 months old that lapsed in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies between 12 and 24 months old that lapsed in the quarter. State the number of policies between 12 and 24 months old that lapsed in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies older than 24 months that lapsed in the quarter. State the number of policies older than 24 months that lapsed in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of benefits that were cancelled by the policyholder in the quarter State the number of policies less than 12 months old made paid-up in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Page 25 of 55

26 LIFE INSURERS Direct marketing via telesales/call centres of any other third party; OF QUESTIONS Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). State the number of policies less than 12 months old made paid-up in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies between 12 and 24 months old made paid-up in the quarter. State the number of policies between 12 and 24 months old made paid-up in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies older than 24 months made paid-up in the quarter. State the number of policies older than 24 months made paid-up in the quarter as per the income group breakdown below: Low income; Middle income; Upper income Page 26 of 55

27 LIFE INSURERS State the number of policies surrendered in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; OF QUESTIONS Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). State the number of policies surrendered, as indicated above, which was due to replacement in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Page 27 of 55

28 LIFE INSURERS Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); OF QUESTIONS Other (please specify). State the number of policies surrendered in the quarter as per the income group breakdown below: Low income; Middle income; Upper income State the number of policies transferred in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). State the number of policies transferred in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of new policies, which were replacement policies, issued in the quarter, as per the breakdown below: Page 28 of 55

29 LIFE INSURERS Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; OF QUESTIONS Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). 2 DISTRIBUTION AND BINDER COSTS Please state the total commission paid in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify) Page 29 of 55

30 2.2 LIFE INSURERS Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below: OF QUESTIONS Enter into, vary or renew a policy; Determining wording of a policy; Determining premiums under a policy; Determining the value of benefits under a policy; Settling a claim under a policy. 2.3 Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter. 3 CLAIMS MANAGEMENT State the number of claims that were reported to the insurer in the quarter. State the value of claims that were reported in the quarter. State the number of claims that were paid in the quarter. State the value of claims that were paid in the quarter. State the number of claims that were repudiated in the quarter. State the value of claims that were repudiated in the quarter. State the number of claims outstanding at the end of the quarter. State the value of claims outstanding at the end of the quarter. 4 COMPLAINTS HANDLING State the number of complaints received in the quarter as per the breakdown below: Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits); Complaints relating to product performance (including but not limited to investment Page 30 of 55

31 LIFE INSURERS performance); OF QUESTIONS Complaints relating to product accessibility, changes or switches (including termination charges); Complaints relating to claims, in relation to: Claim handling process; Claims repudiated. 5 ADD-ON/RIDER BENEFITS Do you offer any of the following benefits 5.1 as add-on/rider benefits to the policies? Retrenchment; Emergency evacuation/transport; Legal Expenses; Cash back/no claim; Loyalty benefit as part of product; Loyalty benefit as part of separate program; Other (please specify). State the number of policies with the addon/rider benefits as per the breakdown below: Retrenchment; Emergency evacuation/transport; Legal Expenses; Cash back/no claim; Loyalty benefit as part of product; Loyalty benefit as part of separate program; Other (please specify). GENERAL SHEET 1 PAYMENTS Please state the total outsourcing fees paid 1.1 to all other parties, including intermediaries and Underwriting Managers, in the quarter. Please state the total advertising and 1.2 marketing expenses paid to all other parties in the quarter as per the breakdown Page 31 of 55

32 1.3 below: LIFE INSURERS OF QUESTIONS Television; Radio; Print media; Social media; Other. Please indicate where possible, the percentage of total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown below: Television; Radio; Print media; Social media; Other. 2 COMPLAINTS 2.1 State the number of all complaints received in the quarter. 2.2 State the number of complaints received in the quarter as per the breakdown below: Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures); Complaints relating to service; Complaints relating to advice in respect of each of the following distribution channels: Insurer's "face-to-face" representatives; Insurer's call centre representatives; Independent FSP's Other Complaints relating to complaints handling process; Other complaints. 2.3 State the number of all complaints finalised in favour of the policyholder in the quarter. 2.4 State the number of all complaints Page 32 of 55

33 LIFE INSURERS outstanding at the end of the quarter. OF QUESTIONS Page 33 of 55

34 CBR s response to industry comments 4.3. TABLE: NON-LIFE INSURANCE Levels 1 and 2 are aligned to the classes and sub-classes in the Insurance Bill. Reporting on level 3 is required in the instances set out in section 4.4 below, where further information is required on specific cover types and or benefits MOTOR a. Personal lines Comprehensive; 3 rd Party; 3 rd Party, fire & theft; Other b. Commercial lines Comprehensive; 3 rd Party; 3 rd Party, fire & theft; Other 2. PROPERTY a. Personal lines Contents; Specified items; Page 34 of 55

35 1 2 3 Building structure; Other b. Commercial lines Contents; Specific item; Building structure; Business interruption; Other 3. AGRICULTURE a. Personal Lines Crop; Equipment; Other b. Commercial lines Crop; Equipment; Page 35 of 55

36 1 2 3 Other 4. ENGINEERING 5. MARINE a. Personal lines b. Commercial lines 6. AVIATION a. Personal lines b. Commercial lines 7. TRANSPORT a. Personal lines b. Commercial lines 8. RAIL 9. LEGAL EPENSE a. Personal lines b. Commercial lines 10. LIABILITY Directors and officers Page 36 of 55

37 1 2 3 Employer liability Product liability Professional indemnity Public liability Aviation Engineering Marine Motor Rail Transport Personal Other Page 37 of 55

38 CONSUMER CREDIT a. Personal Lines - Mandatory Accident & Health; Motor; Property: Specified items; Property: Building structure; Credit Shortfall; Other b. Personal Lines Optional Accident & Health; Motor; Property: Specified items; Property: Building structure; Credit Shortfall; Other Page 38 of 55

39 1 2 3 c. Personal lines - Other d. Commercial lines - Mandatory Accident & Health; Motor; Property: Specified items; Property: Building structure; Credit Shortfall; Other Page 39 of 55

40 1 2 3 e. Commercial lines - Optional Accident & Health; Motor; Property: Specified items; Property: Building structure; Credit Shortfall; Other f. Commercial lines - Other Page 40 of 55

41 TRADE CREDIT 13. GUARANTEE a. Commercial lines 14. ACCIDENT AND HEALTH a. Individual - Personal lines Medical expense shortfall cover (Gap Cover); Non-medical expense cover as a result of hospitalisation (Hospital Cash Back); HIV, Aids, tuberculosis and malaria testing and treatment; International travel insurance; Medical emergency evacuation or transport b. Individual - Commercial lines Medical expense shortfall cover (Gap Cover); Non-medical expense cover as a result of hospitalisation (Hospital Cash Back); Page 41 of 55

42 1 2 3 HIV, Aids, tuberculosis and malaria testing and treatment; International travel insurance; Medical emergency evacuation or transport c. Group Medical expense shortfall cover (Gap Cover); Non-medical expense cover as a result of hospitalisation (Hospital Cash Back); HIV, Aids, tuberculosis and malaria testing and treatment; International travel insurance; Medical emergency evacuation or transport Page 42 of 55

43 TRAVEL a. Individual - Personal lines Loss of Property (including baggage); Cancellation; Interruption; Death, disability or health event while travelling b. Individual - Commercial lines Loss of Property (including baggage); Cancellation; Interruption; Death, disability or health event while travelling c. Group Loss of Property (including baggage); Cancellation; Page 43 of 55

44 1 2 3 Interruption; Death, disability or health event while travelling 16. MISCELLANEOUS a. Personal Lines Warranty; Pet Insurance; Other b. Commercial lines Warranty; Other 17. PERSONAL LINES POLICY WITH MULTIPLE COVER TYPES Motor: Comprehensive; Motor: 3 rd Party; Motor: 3 rd Party, fire & theft; Motor: Other; Property: Contents; Page 44 of 55

45 1 2 3 Property: Specified items; Property: Building structure; Property: Other; Legal Expense; A&H: Personal accident; A&H: Health event other than accident; Miscellaneous: Warranty; Miscellaneous: Other. 18. COMMERCIAL LINES POLICY WITH MULTIPLE COVER TYPES Motor: Comprehensive; Motor: 3 rd Party; Motor: 3 rd Party, fire & theft; Motor: Other; Page 45 of 55

46 1 2 3 Property: Contents; Property: Specified items; Property: Building structure; Property: Business interruption; Property: Other; Agriculture: Crop; Agriculture: Equipment; Agriculture: Other; Legal Expense; Liability: Directors and officers; Liability: Employer liability; Liability: Product liability; Page 46 of 55

47 1 2 3 Liability: Professional indemnity; Liability: Public liability; Liability: Other; A&H: Personal accident; A&H: Health event other than accident; Miscellaneous: Warranty; Miscellaneous: Other. Page 47 of 55

48 CBR s response to industry comments 4.4 QUESTIONS AND REPORTING FOR NON-LIFE INSURERS NON-LIFE INSURERS 1 BUSINESS COMPOSITION State the number of policies in force at the end of the quarter. State the number of cover types in force at the end of the quarter. State the total gross written premium for all policies in force at the end of the quarter. State the number of new policies issued in the quarter. State the number of new cover types issued in the quarter. State the total gross written premium for all new policies issued in the quarter. OF QUESTIONS MAIN State the number of policies issued in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of new policies issued in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); 1 3 Page 48 of 55

49 NON-LIFE INSURERS OF QUESTIONS MAIN Other (please specify). State the gross written premium for new policies issued in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). State the number of policies recorded during the quarter as "not taken up" due to nonpayment of premiums, as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; 1 3 Page 49 of 55

50 NON-LIFE INSURERS Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); OF QUESTIONS MAIN Other (please specify). State the number of policies recorded during the quarter as "not taken up" due to nonpayment of premiums, as per the income group breakdown below: Low income; Middle income; Upper income. State the number of policies cancelled by the policyholder in the quarter State the number of policies cancelled by the insurer in the quarter. State the number of all policies lapsed during the quarter. State the gross written premium for all policies lapsed during the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). 1 3 Page 50 of 55

51 NON-LIFE INSURERS OF QUESTIONS MAIN State the number of policies lapsed in the quarter as per the income group breakdown below: Low income; Middle income; Upper income. State the number of cover types cancelled by the policyholder in the quarter. 2 DISTRIBUTION AND BINDER COSTS Please state the total commission paid in the quarter as per the breakdown below: Direct marketing via telesales/call centre of the insurer; Direct marketing via telesales/call centre of affinity schemes; Direct marketing via telesales/call centres of any other third party; Direct marketing via internet; Marketing via aggregator and/or lead generator; Face-to-face by insurer s own individual representatives ( tied agents ); Face-to-face by insurer's juristic representatives; Face-to-face by independent intermediaries (FSP s that are not representatives of the insurer); Other (please specify). Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below: Enter into, vary or renew a policy; Determining wording of a policy; Determining premiums under a policy; Determining the value of benefits under a policy; Settling a claim under a policy. 1 3 Page 51 of 55

52 NON-LIFE INSURERS OF QUESTIONS MAIN 2.3 Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter CLAIMS MANAGEMENT State the number of claims that were reported to the insurer in the quarter. State the value of claims that were reported in the quarter. State the number of claims that were paid in the quarter. State the value of claims that were paid in the quarter. State the number of claims that were repudiated in the quarter. State the value of claims that were repudiated in the quarter. State the number of claims outstanding at the end of the quarter. State the value of claims outstanding at the end of the quarter. 4 COMPLAINTS HANDLING State the number of complaints received in the quarter as per the breakdown below: Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits); Complaints relating to product performance (including but not limited to investment performance); Complaints relating to product accessibility, changes or switches (including termination charges); Complaints relating to claims, in relation to: Claim handling process; Claims repudiated. 5 ADD-ON/RIDER BENEFITS Page 52 of 55

53 5.1 NON-LIFE INSURERS Do you offer any of the following benefits as add-on/rider benefits to the policies? OF QUESTIONS MAIN Emergency evacuation/transport; Legal Expenses; Riots and strikes; Cash back/no claim; Loyalty benefit as part of the product; Loyalty benefit as part of separate program; Other (please specify). State the number of policies with the addon/rider benefits as per the breakdown below: Emergency evacuation/transport; Legal Expenses; Riots and strikes; Cash back/no claim; Loyalty benefit as part of the product; Loyalty benefit as part of separate program; Other (please specify). Page 53 of 55

54 NON-LIFE INSURERS GENERAL SHEET 1 PAYMENTS Please state the total outsourcing fees paid to all other parties, including intermediaries and Underwriting Managers, in the last quarter. Please state the total advertising and marketing expenses paid to all other parties in the last quarter as per the breakdown below: OF QUESTIONS MAIN Television Radio Print media Social media Other Please indicate where possible, the percentage of total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown below: Television Radio Print media Social media Other 2 COMPLAINTS State the number of all complaints received in the quarter. 2.2 State the number of complaints received in the quarter as per the breakdown below: Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures); Complaints relating to service; Complaints relating to advice in respect of each of the following distribution channels: Insurer's "face-to-face" representatives; Insurer's call centre representatives; Page 54 of 55

55 Independent FSP's Other Complaints relating to complaints handling process; Other complaints. State the number of all complaints finalised in favour of the policyholder in the quarter. State the number of all complaints outstanding at the end of the quarter. Page 55 of 55