2015 Star Ratings. Creditor Insurance. Discussion paper

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1 2015 Star Ratings Creditor 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 1 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 Creditor Insurance covering Mortgage PPI and Short Term 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 The creditor insurance market is struggling to recover from the fallout from the PPI misselling scandal. The focus is now on Mortgage Payment Protection Insurance (MPPI), which did not account for the greater share of the complaints, and Short Term Income Protection (STIP). The need is as great as ever and the draconian remedies, intended to protect the public from making bad decisions, effectively make it more difficult for the industry to deliver products to clients. The point of sale prohibition (POSP), which precludes a firm from selling creditor insurance products to clients at the same time that it arranges finance for them means that clients have a seven-day window to shop around for more suitable cover before the firm can approach them about MPPI or STIP. Unfortunately, this may result in clients with genuine needs not getting the cover they need. The standalone market for MPPI and STIP is wide open and providers perceive an opportunity. There has been a rush of products available online but in the absence of any reliable source of sales figures, it is unclear how big an opportunity it is; anecdotally, little is being sold. Challenges and opportunities are presented by: Mortgage Market Review HMT Simple Products Initiative Income Protection Taskforce Legislation and regulation Mortgage Market Review (MMR) The MMR set out the case for reforming the mortgage market to ensure it is sustainable and works better for consumers. Its provisions, which came into effect in April, are in essence 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 therefore potentially less time to consider the client s protection needs. Second, a more rigorous assessment of affordability, which has to take into account insurance outgoings, may mean people with protection insurances will not pass the affordability test. Both MPPI and STIP are products that are relevant for people with mortgage debt and, under the Mortgage Code, the FSA and now the FCA have always required that an adviser ensures their client is at least aware of the benefits of income replacement insurance. 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. MMR is both a challenge and an opportunity for creditor insurers and distributors. 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 3

4 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 blue print 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 long term income protection within the industry and beyond. 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. So whilst primarily promoting the benefits of long term income protection insurance, the opportunity exists for short term insurers and distributors to promote their activities on the back of the publicity and messaging; indeed one major creditor insurer has signed up as a sponsor of the initiative. The IPTF is also working on a code of conduct to improve standards and reassure the public. Its work on means-testing 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 income protection when taking into account their entitlement to state benefits. All these initiatives will help to create awareness of people s financial vulnerability if they can t work and hopefully create greater demand for income replacement and debt protection products. Providers There are 45 MPPI plans from 35 providers and 56 STIP products from 36 providers. We categorise the providers into four broad types: banks/building societies, brokers/broker networks, web distributors and insurers. The following chart shows the percentage of STIP products by provider type. 4

5 The providers are mainly web distributors offering products direct to consumers and insurers offering products direct and through intermediaries. Comparing the types of providers with last year, we see that there are more insurers and web distributors and fewer banks/building societies and brokers acting as providers. A similar analysis for MPPI would show this trend to be very marked with banks/building societies largely bailing out of creditor insurance sales. Products/propositions This following chart shows creditor insurance products year on year since It illustrates that, purely in terms of the number of products available, personal loan PPI and credit card PPI have drastically declined and all but disappeared; MPPI has declined but is still holding its own; but STIP is in the ascendancy. There are fewer MPPI products - just 47 at the end of 2013 (45 to date); and there are also fewer STIP products too - 62 at the end of the year (56 to date). The proliferation of products has been down to the introduction of web-based products hoping to cash in on the standalone market for STIP and some of these, it would appear, have not been successful and have been withdrawn. There is no reliable source of STIP sales volumes but they are felt to be relatively small. D2C distribution models rely on consumers wanting to buy and that desire does not appear to be there yet MPPI PL PPI CC PPI STIP Number of products year on year Source: Defaqto 5

6 During the course of the last year we have seen new STIP products from ESMI, DMS, British Money and Best Insurance and a rebrand of Berkeley Alexander s Safety First policies. We have also seen 18 products withdrawn. A typical STIP policy offers a choice of cover: either accident, sickness and unemployment (ASU) or accident and sickness (AS); it has a 12 month benefit period; pays up to 50% of income or 2,000 per month; it has a choice of excess periods (30, 60 or 90 days); offers optional back-to-day-one cover; and is marketed D2C. 6

7 Key implications for the 2015 Ratings process No changes are proposed to the database or the Star Ratings criteria as a result of these developments this year. However, there are a number of issues to consider for future inclusion. The PPI misselling scandal has left its mark on the creditor insurance market and restoring reputation in the face of widespread consumer mistrust is a key challenge. People need to feel confident that their policy will pay out if they need to claim. The industry should consider publishing claims paid statistics. Provided there is a good story to tell, this will help to allay consumer fears and will challenge less scrupulous firms to up their game. Providers should aim to reduce exclusions to a minimum and not restrict cover for the main causes of work absence, that is, mental health issues and back problems. These should be covered as standard. Providers must review their definitions for claim so that consumers are clear when they can claim and when they cannot. Some definitions seem to suggest that a pay-out would not be forthcoming if the claimant were capable of doing any work at all. The following tables set out the current criteria for STIP and MPPI 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 4 or 5 Star Rating. Features matching benefits to needs (23% of criteria) Cover Options Back to Day One Cover (BTDO) Benefit Period Options Excess/BTDO Selectable Excess Options Deferral Period - AS Deferral Period - U Excess Options Features relating to the benefits and cover (19% of criteria) Carer Cover Joint Cover Splits MPPI Only Max Additional Cover MPPI Only Maximum Monthly Benefit STIP Only Max Earnings % STIP Only Payment Method Benefit Type Core criterion for 4 and 5 Stars 7

8 Qualification periods (19% of criteria) Initial Exclusion Accident and Sickness Initial Exclusion Unemployment (New) MPPI Only Initial Exclusion Unemployment (Exist) MPPI Only Initial Exclusion Unemployment STIP Only Previous Illness Period Core Criterion for 4 and 5 Stars PEC Qualification Period Core Criterion for 4 and 5 Stars Temporary Work Period Core Criterion for 4 and 5 Stars Features relating to claiming under the policy (17% of criteria) Disability Continuation Unemployment Continuation Recurring Illness Period New Claim - Illness New Claim - Unemployment Definition of Disability Cover/exclusions (11% of criteria) Chronic Conditions Stress Backache Core Criterion for 4 and 5 Stars Core Criterion for 4 and 5 Stars Core Criterion for 4 and 5 Stars Self Employed Allowed Help and assistance (3% of criteria) Back to Work Help Cover continuity (8% of criteria) Cover Transfer Cancellation - No Sub Change Days 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 Roundtable event. What measures that work towards improving the reputation of the creditor insurance market should be evidenced by criteria in the Star Rating for example claims data, exclusions from cover? Are there any other features and benefits of MPPI and STIP, which are not currently covered within the existing criteria set, that should form part of it going forward? Specifically, should the help and assistance programmes provided by some insurers receive credit within the Rating criteria? Are there any existing criteria which should not form part of the Ratings going forward? 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 Mortgage Payment Protection Insurance Cover Options Available Initial Exclusion Unemployment (New) Benefit Period Options Initial Exclusion Unemployment (Exist) Excess Options Disability Continuation Back to Day One Cover Unemployment Continuation Excess/BTDO Selectable Recurring Illness Period Definition of Disability New Claim Illness Self Employed Allowed New Claim Unemployment Cover Transfer Temporary Work Period Carer Cover Back to Work Help Joint Cover Splits Previous Illness Period Maximum Additional Cover Pre-Existing Condition Qualification Period Payment Method Chronic Conditions Benefit Type Stress Deferral/Excess Period Accident and Sickness Backache Deferral/Excess Period Unemployment Cancellation No Substitute Initial Exclusion Accident and Sickness Change Days 10

11 Proposed criteria Short Term Income Protection Insurance Cover Options Available Initial Exclusion Unemployment (days) Benefit Period Options Disability Continuation Excess Options Unemployment Continuation Back to Day One Cover Recurring Illness Period (days) Excess/BTDO Selectable New Claim Illness Definition of Disability New Claim Unemployment Self Employed Allowed Temporary Work Period Cover Transfer Back to Work Help Carer Cover Previous Illness Period Maximum Monthly Benefit ( ) Pre-Existing Condition Qualification Period Max Earnings (%) Chronic Conditions Payment Method Stress Benefit Type Backache Deferral/Excess Period Accident and Sickness Cancellation No Substitute (days) Deferral/Excess Period Unemployment Change Days Initial Exclusion Accident and Sickness 11

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