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Emerging cross-country insights • Business models and their regulatory implications • Regulatory approaches Hennie Bester, 17 July 2013 Drafting Group meeting: Issues paper Market Conduct, Distribution and Consumer Protection in Inclusive Insurance Markets Manila, Philippines Introduction • A2ii synthesis process: develop three thematic notes to synthesise trends and issues across countries on key microinsurance policy, regulatory and supervisory topics • Scope of notes determined by A2ii Technical Team: • First note - Evolving microinsurance business models and their regulatory implications • Second note - Different approaches taken by regulators to catalyse microinsurance markets and their impact • Third note - Input into forthcoming IAIS issues paper on market conduct, distribution and consumer protection specifically related to microinsurance 2 Information sources Country China India Mongolia Nepal Pakistan Philippines Brazil Colombia Mexico Peru Ethiopia Ghana Kenya MI Diagnostic/ country study MI-specific regulations * Country Nigeria Uganda Lesotho Mozambique South Africa Swaziland Tanzania Zambia Botswana Namibia Malawi Zimbabwe MI Diagnostic/ country study MI-specific regulations * * * * * * * *Proposed 3 Note 1 Evolving microinsurance business models and their regulatory implications: 1. How do we categorise the various business models? 2. What are they and how do they evolve? 3. Risks distinctive to microinsurance business models? 4. What are the regulatory implications & responses? 4 Note 1 Evolving microinsurance business models and their regulatory implications: 1. How do we categorise the various business models? 2. What are they and how do they evolve? 3. Risks distinctive to microinsurance business models? 4. What are the regulatory implications & responses? 5 Business Models: categorisation • • • • Preferred approach: nature of intermediation process Different forms of intermediation present different risks Underwriting risks also relevant Nature of the risks determine regulatory responses Intermediation Risks Regulatory Responses 6 Business Models: categorisation Why emphasise intermediation? Hence intermediation is the main parameter by which we define discrete business models And from a supervisor’s perspective intermediation is the most definitive aspect due to the increased risks as a result. Intermediation Supervisor The issue of intermediation is even more important in MI because of factors like difficulties in access, low premiums and values meaning high volumes needed etc. Microinsurance Intermediation is the method of linking a buyer and a seller Business Model Insurance A business model (generally i.e. for any business) is fundamentally about how to link a buyer with a seller Intermediation is particularly important in insurance because insurance is sold and not bought 7 Business Models: value chain Intermediation channel Traditional insurance: Reinsurer Administration Insurer Broker/agent Payments Clients Integrated Technology Platform vs. Microinsurance: longer value chain Intermediation channel Reinsurer Insurer Administrator Payments provider Broker/agent Integrated Technology Platform Aggregator Clients Note 1 Evolving microinsurance business models and their regulatory implications: 1. How do we categorise the various business models? 2. What are they and how do they evolve? 3. Risks distinctive to microinsurance business models? 4. What are the regulatory implications & responses? 9 8 discrete business models 1. 2. 3. 4. 5. 6. 7. 8. Individual sales Proxy sales force Compulsory sales Group decision Local self-help Auto enrolment Passive sales Service-based sales 10 Model 1: Individual sales Role Underwriter Insurer Product development Premium collection Description: One on one active sales through Administration fulltime insurance agents or brokers, including Marketing by inoutbound call centres; can be supported Sales bound call centres; no client aggregator involved. Agent / Broker / Call centre C C C C C C Evolution: - Traditional sales model that insurers extend down-market for MI in parallel to or before Insurance decision experimenting with alternative mass distribution channels - Post-alternative distribution movement “back to the agent” where advantage of face-to-face interaction becomes apparent Examples: SINAF Seguros, Grupo Villa (Brazil), Metropolitan REI (South Africa) 11 Model 2: Proxy sales forces Description: Insurance sold to existing clients ofRole noninsurance entities where the policy is marketed with the sale Underwriter of another product. Active sales persons involved, but the development salesperson works for the aggregator andProduct the insurance is ancillary to the primary good that they sell.Administration Product can be standalone (cross-selling to third party client base) or embedded in underlying service. Insurance decision is voluntary in the case of cross-selling, Sales but often compulsory in the case of embedded credit life. Insurer Retailer/ Utility / Bank/ Credit provider S S Sales force S Marketing Consolidating data Evolution, cross-selling: - Instigated by the insurer , aggregator or 3rd party. Premium collection - Evolves from aggregators wishing to diversify income - For insurers, aggregator represents an easy existing contact point to the target market Insurance decision Embedded credit life: - Evolves from the demand for credit and the need to protect the default risk for the credit supplier. - Often first product sold in microinsurance market. S S C C C C C C Examples: Credit life; Bancassurance; Retailer sales: Casas Bahia (Brazil); Utilities: Codensa Mapfre (Colombia) 12 Model 3: Compulsory Role Prescribe product Regulation parameters Underwriter Insurer Insurer Insurer Product development Premium collection Administration Description: Insurance required by regulation for certain categories of citizens. Marketing Agent C Agent C C Agent C C C Evolution: Sales - In response to specific public needs, eg protection of road users; health needs of employed population - Often the "beginning" of asset insurance Purchase decision market Examples: Third party motor vehicle insurance (most countries) Social health insurance for formally employed 13 Model 4: Group decision Role Underwriter Insurer Product development Premium collection Broker / Agent Administration Description: Members of a group become policyholders by virtue of group rather than individual decision; collective negotiation; eitherMarketing universal cover by virtue of membership of group or opt-in Sales Premium collection C Evolution: - Evolves where there are existing groups which reduce distribution costs Premiumof collection - Insurers leverage the member database the groups Insurance decision - Groups offer value added services to members Group C C C C C Examples: Labour unions (Doves, South Africa), PASI (Brazil), China village model; cooperatives; Association of Tanzania bus drivers, Protecta partnership with educational institutions (Peru) 14 Model 5: Local self-help Role Group Underwriter C C Product development C C Premium collection C C Insurance decision C C Administration C C Description: Group of persons pool own risks C C Non-members Evolution: - Develops in the absence of appropriate/accessible formal alternatives or If non-members where people do not trust formal options or allowed: prefer own provision on the basis of solidarity Sales - Strong community ties Marketing Examples: Philippines MBAs; funeraria and cooperatives, burial societies 15 Model 6: Auto enrolment 3rd Description: party purchases insurance on behalf of policyholders. This may be the government subsidising Prescribe product insurance on behalf of class of citizens or a 3rd party Procurement aggregator such as an MNO or bank purchasing Subsidise premium insurance for its clients as a loyalty scheme. There is Premium collection commercial underwriting.. 3rd party decision & funding Insurer C Insurer C C Insurer C C Role C Underwriter Evolution, public provision: - Develops from a strong state mandate & social Administration goals Claims payment - May be a response to market failures Loyalty benefits: - Value added service Broker to reduce clientused churn & agents for distribution - 3rd party ‘market-maker’ such as innovative broker “Market maker” administrator for - Opportunity for extending the reach of the insurance loyalty schemes market in undeveloped markets Claimsin India (RSBY), state Examples: Health insurance funded agricultural insurance (NAIS, India); disaster risk in rural China; Waseela BISP (Pakistan); MNO loyalty schemes: TIGO BIMA (Tanzania), TIGO (Ghana) 16 Model 7: Passive sales Role Underwriter Product development Insurer Premium collection Administration Marketing Marketing Passive channel Description: Individual purchases insurance without Passive sales intervention of sales person Premium collection Administration Evolution: - Particular insurance product has become Insurance decision "commoditised.“ - Market familiar with the concept of insurance - Atypical in undeveloped markets. C C C C C C Examples: Internet sales; Clientele hospital cash plan (South Africa), Pep/Hollard (South Africa); inbound call centres 17 Model 8: Service-based sales Role Underwriter Provider S Product development S Salesforce S Premium collection S Administration S Description: Securing a service to beMarketing rendered in the future through an insurance policy. Voluntary individual Sales choice. The entity which sells the insurance is the same providerby one that provides the service. May beService underwritten the provider or by an insurer. Evolution: Insurance/ product - Driven by strong demand for underlying service decision - Client cannot afford service without insurance - Does not require a well developed insurance sector to evolve C C C C C C Examples: Health insurance provided by health service providers; funeral assistance; funeral parlours in Colombia and Brazil 18 Scenarios of evolution Scenario Description Models Bottom up spontaneous development Insurance evolves spontaneously on the back of underlying consumer needs and to fill gaps in formal provision. Service-based sales, Local self help External market catalyst Both insurers and aggregators are comfortable in their traditional market segments with limited capacity for expansion. A third party such as a corporate broker or administrator sees the opportunities for market making and starts to match insurers and groups Loyalty auto-enrolment, Group decision, Proxy sales force State driven The public provision model dominates. It can either crowd out private provision in the low-income end of the market, or public provision can leverage the market mechanism, thereby building capacity and triggering interest among private insurers to provide top-up cover or to reach parts of the market not provided for by public provision. May play out in parallel with bottom up scenario Government autoenrolment Competitive dynamics Market competitive pressures and innovative players mean that the market "takes on" the mass market challenge and works with third parties to implement alternative distribution. Can stem from competition in insurance or amongst potential aggregators e.g. MNOs wishing to provide additional benefits to subscribers. Loyalty auto-enrolment, Passive sales, Proxy sales force, Group decision, Individual sales Service provider needs Where insurance is used to mitigate client financial risk for service providers such as credit providers (where insurance takes the place of collateral for low income clients not able to provide collateral) or where service providers sell insurance to promote securing of underlying service, e.g. funeral service providers for funerals and medical service providers where clients not able to make single bulky payments for treatment. Credit life, Servicebased sales 19 Note 1 Evolving microinsurance business models and their regulatory implications: 1. How do we categorise the various business models? 2. What are they and how do they evolve? 3. Risks distinctive to microinsurance business models? 4. What are the regulatory implications & responses? 20 6 discrete microinsurance risks 1. 2. 3. 4. 5. 6. Prudential risk Aggregator risk Sales risk Policy awareness risk Payments risk Post sales risk 21 Microinsurance risk categories Risk category Description Prudential risk Risk that insurer not able to keep its promises & deliver the benefits to the beneficiaries. Aggregator risk The risk of reduced client value and inappropriate products being sold to clients when an insurer accesses the aggregated client base of a noninsurance third party to sell its products through that channel. Sales risk Risk that the salesperson will misrepresent the product to the client or sell a product that the client does not need. 22 Microinsurance risk categories Risk category Description Policy awareness risk Risk that the insured is not aware that he or she has an insurance policy and is therefore unable to lodge a claim should the risk event occur. Payment risk Risk that the premium will not reach the insurer, that the premium will not be paid on the due date or that the cost of collecting the premium is disproportionate. Post sale risk Risk that clients face unreasonable post-sale barriers to maintain their cover, change products, make enquiries, submit claims, receive benefits or make complaints. 23 Microinsurance risk categories Description Risk category Prudential risk Risk drivers Risk that insurer not • Capacity (risk management capacity, financial management capacity, product design able to keep its capacity, etc.) of the underwriter - which leads amongst others to the design of inappropriate promises & deliver products the benefits to the • Lack of supervision of the underwriter - which can be caused by the informality of the beneficiaries. underwriter (it is not licensed and therefore not subject to supervision), or the lack of capacity of the supervisor • Underwriter is too small (scale issue), particularly in relation to the size of the risk pool • Inadequate corporate governance • Aggregator The risk of reduced risk client value and • inappropriate products being sold to clients when an insurer accesses the • aggregated client base of a noninsurance third party • to sell its products through that channel. • Lack of actuarial data for the particular target market to enable sound pricing Disproportionate bargaining power between insurer and aggregator where the latter owns the clients through a prior business relationship; (aggregator need for brand protection can act as mitigating factor) Bargaining power of the aggregator vis-a-vis the client is inserted in the purchasing decision between the insurer and the client - especially prevalent in credit Financial risks and interests of the aggregator (as opposed to the client), e.g. credit risk, risk of product defects Terms of contractual relationships between the insurer and aggregator and insured • Limited availability of mass distribution channels in a particular market 24 Microinsurance risk categories Description Risk category Sales risk Risk drivers Risk that the • Sales persons have insufficient knowledge and skills to sell insurance products of the kind salesperson will sold to the target market misrepresent the product to the client • Incentives for the salespersons are misaligned with the interests of the client, for example or sell a product that there is no incentive to ensure policy renewals (such as up front commissions only); or the the client does not commissions are capped at a level which discourages sales effort; or the incentives are to need. sell the product or service in which the insurance is embedded (such as credit) rather than the insurance product. • Inadequate accountability of sales persons Policy Risk that the insured • Absence of a specific sales action, for example in the case of automatic enrolment for a awareness is not aware that he publicly funded insurance benefit or a loyalty-type insurance product. risk or she has an insurance policy and is therefore unable to • “Tick box” sales process, for example with embedded products lodge a claim should the risk event occur. • Low level of financial literacy on the side of the client 25 Microinsurance risk categories Description Risk category Risk drivers Risk that the premium • will not reach the insurer, that the premium will not be • paid on the due date • or that the cost of collecting the premium is disproportionate. Post Sales Risk that clients face • risk unreasonable post- • sale barriers to maintain their cover, change products, • make enquiries, submit claims, • receive benefits or make complaints. • Payments risk Presence of an intermediary between the insurer and aggregator or client who can delay payment of the collected premium to the insurer or neglect to make the payment at all. Seasonal or irregular income of clients which cause them to miss monthly or other set dates for payment of premiums. Mandatory payment system requirements that apply to premium collection, for example that it has to be paid through a bank. Clients with limited knowledge and experience of insurance. Lack of reasonable access to the insurer or the intermediary after the sale (low income clients prefer personal contact - a person or a branch to go to). Faceless insurers (from the client’s perspective) who underwrite policies distributed by third parties. Unscrupulous insurers, notably in countries with compulsory insurance, coupled with inadequate supervision. Manner in which group underwriting is done, notably when there is selective non-renewal of cover by insurers. • Incidence or past history of monopolistic insurance provision. • Risk can also come from the community, for example where there are cultural fears of autopsy and the insurance company requires an autopsy report to pay the claim on a life policy. • Unreasonable requirements from insurers to submit claims. 26 Risk matrix Prudential Aggregator Sales risk Policy Awareness Payments Post sales risk risk risk risk risk x Individual sales x Proxy sales forces Compulsory sales x x x x x x x x Auto enrolment x Passive sales Service-based sales x x x x Group decision Local self-help x x x x x x 27 Note 1 Evolving microinsurance business models and their regulatory implications: 1. How do we categorise the various business models? 2. What are they and how do they evolve? 3. Risks distinctive to microinsurance business models? 4. What are the regulatory implications & responses? 28 Regulatory Implications of MI business models MI business models: issues arising Implications for supervisors Involvement of multiple parties in delivering the insurance product • Longer value chain means more entities, not all of them under supervisor’s jurisdiction or traditionally allowed for in insurance regulatory framework. • Accountability of entities can be problematic if not primarily supervised by insurance supervisor. • Broader suite of distribution outlets imply proliferation of insurance agents/sales representatives • Need for intra-agency coordination, especially with other financial sector regulators and telecoms - so that the insurance supervisory objectives can be achieved in respect of entities that do not traditionally fall within the insurance supervisor’s jurisdiction. • Need to make all entities functionally accountable to insurance supervisor for insurance-related services rendered • Delegated supervision may be required to deal with multitude of additional intermediaries involved Reduced skills and competence of persons selling insurance • Non-traditional agents and representatives and proxy sales forces have different skills set to traditional brokers or agents, do not necessarily have insurance experience or qualifications • May not have sufficient knowledge and skills to sell insurance products of the kind sold to the target market • Need to adapt intermediary entry and ongoing requirements in line with new market realities • Must find balance in allowing broader set of intermediaries while not sacrificing consumer protection • May require alternative ways of ensuring competence, e.g. product-specific training rather than prior qualification or experience 29 Regulatory Implications of MI business models MI business models: issues arising Implications for supervisors Misaligned incentives for sales persons or channel • In the case of proxy sales forces, service-based channels, auto enrolment, passive sales and even group decisions, the interests for the sales channel are primarily aligned to that of the third party, underlying service or group, and may be misaligned with the interests of the individual client. • E.g. need to mitigate credit default risk, build customer loyalty, or motivation to sell underlying service or primary goods or services sold by cross-selling partner May need to adapt regulatory framework to align incentives, e.g.: • reconsider commission structures and interplay with incentives • consider code of conduct and other instruments (e.g. cooling off period) to ensure all act in consumers’ best interests • reconsider consumer recourse options • Ensuring consumer choice in whether and which insurance to take Reduced bargaining power of insurer vis-à-vis new intermediaries in the distribution chain The microinsurance value chain is often based on partnerships between insurers and third party aggregators that provide access to their client base. This leads to a situation of unbalanced bargaining power, as the aggregator ‘owns’ the clients and can therefore demand substantial sums from the underwriter in exchange for (often exclusive) access to their database. Need to strengthen bargaining power of insurer, e.g. by: • Requiring identity of insurer to be disclosed • Requiring direct contractual relationship between insurer and client • Requiring disclosure of contract between insurer and aggregator to supervisor Increased distribution costs The combination of a longer value chain, with more entities to remunerate along it, as well as enhanced bargaining power of those parts of the value chain controlling access to the client base may lead to increased distribution costs for lower relative value for the clients. Need to monitor cost trends and resultant consumer value and respond if required, e.g. by: • Monitoring (requiring reporting of) claims and expense ratios • Mandatory disclosure of commission and cost structure • Publishing comparative distribution costs to promote competitive forces 30 Regulatory Implications of MI risks MI business models: issues arising Implications for supervisors Increased reputational risk for insurers As a result of the dominance of non-insurance interests in the longer microinsurance value chain, the insurer is often no longer a strong driver of the client interface. This can lead to increased reputational risk, should an action of the channel lead to a mis-sold policy, to policy awareness risk or to post-sale risk. Need to consider ways in which to ensure that the client interface treats customers fairly and will result in valid claims, e.g. by: • Considering a code of conduct for all intermediaries • Imposing explicit disclosure and simplification requirements • Regulating the process, allowed requirements and maximum time for claims payments • Reconsidering the effectiveness of consumer recourse options Enhanced consumer protection concerns due to nature of target market • Clients have limited knowledge and skills to make informed decisions • Reduced bargaining power of client vis-à-vis insurer and intermediary • Clients have fewer resources to access consumer recourse mechanisms which can undermine the effectiveness of independent or third party recourse mechanisms Need to ensure that the sales process and the information disclosed during it speak to the realities of the target market, e.g. by: • Public consumer awareness and education campaigns • Product simplification requirements, for example plain language and limited exclusions - linked to file and use or prior product approval • Explicit disclosure requirements, i.e. minimum terms and conditions to be disclosed to the client verbally and/or in writing, often linked to a requirement that it be done in the vernacular • Reconsidering the effectiveness of consumer recourse options 31 Regulatory responses Risk trigger Regulatory response Risk Impact Regulatory responses: Prudential risk Risk description Prudential risk: Risk that insurer not able to keep its promises & deliver the benefits to the beneficiaries Risk drivers • Capacity (risk management capacity, financial management capacity, product design capacity, etc.) of the underwriter - which leads amongst others to the design of inappropriate products Observed responses • Lower entry and compliance requirements for underwriters (tiering or concessionary approach), while retaining a minimum entry requirement to weed out entities that are too small - primarily here to entice entities into formal supervision • Lack of supervision of the underwriter - which can be caused by the informality of the underwriter (it is not licensed and therefore not subject to supervision), or the lack of capacity of the supervisor • Permitting wider spectrum of legal entities other than public companies, for example mutual or mutual-type entities and civil society organisations, to become underwriters • The underwriter is too small (the scale issue), particularly in relation to the size of the risk pool • Inadequate corporate governance • Product restrictions to reduce prudential risk eg benefit or premium caps, term restrictions, restrictions on insurance risks - or prescribing specific pricing formulas to apply • Prior approval of products to check actuarial soundness of pricing • Simplified but regular reporting to supervisor • Separation of business requirement • Lack of actuarial data for the particular target market to enable sound pricing. • Minimum corporate governance requirements • Minimum threshold for size of risk pool 33 Regulatory responses: Aggregator risk Risk description Risk drivers Aggregator risk: • Disproportionate bargaining power between The risk of reduced client insurer and aggregator where the latter owns value and inappropriate the clients through a prior business products being sold to relationship (aggregator need for brand clients when an insurer protection can act as mitigating factor) accesses the aggregated client base of a noninsurance third party to sell its products through that • Bargaining power of the aggregator vis-a-vis the client is inserted in the purchasing channel. decision between the insurer and the client especially prevalent in credit Observed responses • Impute by law a direct insurance relationship between insurer and insured irrespective of contractual relationship between aggregator and client • Disclosure of contract between the insurer and the aggregator to the supervisor • Prohibition on making extension of credit or purchase of good conditional on entering into a related insurance policy • Prohibition on credit provider requiring lender to enter into an insurance policy with a specified insurer - i.e. mandatory choice of insurer even though the insurance policy may be mandatory • Financial risks and interests of the aggregator, • Mandatory reporting of claims ratios and expense e.g. credit risk, risk of product defects ratios to supervisor • Mandatory disclosure of commission and cost structure to the client • Terms of contractual relationships between the insurer and aggregator and insured • Public disclosure of comparative statistics on distribution cost by the supervisor, for example on the internet (transparency rules) • Limited availability of mass distribution • Prior approval of products to check cost structures channels in a particular market • Caps on aggregate intermediation costs (commission and other costs combined) 34 Regulatory responses: Sales risk Risk description Risk drivers Sales risk: • Sales persons have insufficient knowledge Risk that the salesperson and skills to sell insurance products of the will misrepresent the kind sold to the target market product to the client or sell a product that the client does not need. • Incentives for the salespersons are misaligned with the interests of the client, for example there is no incentive to ensure policy renewals (such as up front commissions only); or the commissions are capped at a level which discourages sales effort; or the incentives are to sell the product or service in which the insurance is embedded (such as credit) rather than the insurance product. Observed responses • Minimum qualification and training (including time and training content) requirements for sales persons, often as a dedicated microinsurance agent category of intermediary • Registration requirements for sales persons sometimes registration obligation is delegated to the relevant insurer with a reporting duty to the supervisor • Uncapped commissions • Mandatory structuring of commissions to include both an upfront and an “as and when” component • Prescribed code of conduct of (microinsurance) sales persons • Product simplification requirements, for example plain language and limited exclusions - linked to file and use or prior product approval • Explicit disclosure requirements, i.e. minimum terms and conditions to be disclosed to the client verbally and/or in writing often linked to a requirement that it be done in the vernacular • File and use requirement for mass communication materials proposed to be used by insurer • Statutory cooling off period during which the insured can withdraw from the insurance contract 35 Regulatory responses: Sales risk (Continued) Risk description Risk drivers Sales risk: • Inadequate accountability of sales persons Risk that the salesperson will misrepresent the product to the client or sell a product that the client does not need. Observed responses • Insurers made liable/ responsible for all the actions of their intermediaries as if the latter were their employees • Mandatory complaints resolution procedure to be maintained by the insurer (usually at its own cost rather than on a user charge basis) with or without minimum performance standards for the complaints resolution process 36 Regulatory responses: Policy awareness risk Risk description Risk drivers Policy awareness risk: • Absence of a specific sales action, for Risk that the insured is not example in the case of automatic enrolment aware that he or she has for a publicly funded insurance benefit or a an insurance policy and is loyalty-type insurance product. therefore unable to lodge a claim should the risk event occur. • “Tick box” sales process, for example with embedded products. • Low level of financial literacy on the side of the client Observed responses • Requirement for post-sales communication to the insured within a specified period, for example 30 days, from the date on which he or she entered into the insurance policy (especially in embedded products) • Dedicated communication campaign targeting the insured population • Moving from a fully publicly funded to a part contribution system, i.e. not full subsidy and automatic enrolment, but part subsidy, part premium payment by insured. • Mandatory choice between multiple insurers in the case of compulsory products to make the insurance sales process more explicit to the client. 37 Regulatory responses: Payments risk Risk description Risk drivers Observed responses Payments risk: • Presence of an intermediary between the • Maximum period set within which premiums must Risk that the premium will insurer and aggregator or client who can be paid by intermediary collecting them to the not reach the insurer, that delay payment of the collected premium to the insurer. the premium will not be insurer or neglect to make the payment at all. • Requirements to ensure the financial soundness of paid on the due date or intermediaries and ring-fence premiums collected that the cost of collecting the premium is disproportionate. • Receipt of premium by intermediary imputed to be receipt of premium by insurer • Seasonal or irregular income of clients which cause them to miss monthly or other set dates for payment of premiums. • Mandatory payment system requirements that apply to premium collection, for example that it has to be paid through a bank. • Statutory grace period (during which cover remains in place) if premium not paid when due. Length of the grace period can be made proportionate to how long the policy has been maintained. • More flexible premium collection options/ payment system options. • Regulate the structure of payments to facilitate irregular or lump sum payments. 38 Regulatory responses: Post sales risk Risk description Post sales risk: Risk that clients face unreasonable post-sale barriers to maintain their cover, change products, make enquiries, submit claims, receive benefits or make complaints. Observed responses Risk drivers • Clients with limited knowledge and experience • Liberalisation of the insurance market. of insurance. • Public consumer awareness and education campaigns. • Lack of reasonable access to the insurer or • Registration and training of salespersons. the intermediary after the sale (low income clients prefer personal contact - a person or a • Prohibition on selective cancellation of individual branch to go to). cover within a group policy. • Faceless insurers (from the client’s • Insurers to provide option of a monetary benefit perspective) who underwrite policies instead of an in-kind benefit. distributed by third parties. • Unscrupulous insurers, notably in countries • Prohibition on deductibles in microinsurance with compulsory insurance, coupled with policies. inadequate supervision. • Prescriptions regarding documentation that may be required by an insurer to settle a claim (for • Manner in which group underwriting is done, example, that it shall be kept to a minimum or be notably when there is selective non-renewal limited to specified documents) of cover by insurers. • Maximum periods for claims processing and claims • Incidence or past history of monopolistic payment. insurance provision. • Insurers to maintain client recourse systems with or • Risk can also come from the community, for without minimum performance standards. example where there are cultural fears of autopsy and the insurance company requires • Insurer to handle all microinsurance complaints in the first instance before any further recourse is an autopsy report to pay the claim on a life permitted. policy. • Clear communication (verbally and/or in writing) of • Unreasonable requirements from insurers to available recourse mechanisms to client, including submit claims. 39 the identity of the underwriter. Note 2 Regulatory approaches to the promotion of inclusive insurance markets 1. What is a regulatory approach? 2. Which approaches exist? 3. What triggers a particular regulatory approach? 4. What is the impact of different approaches? 40 Note 2 Regulatory approaches to the promotion of inclusive insurance markets 1. What is a regulatory approach? 2. Which approaches exist? 3. What triggers a particular regulatory approach? 4. What is the impact of different approaches? 41 What is a regulatory approach? Policy objectives for access to financial services Political, economic & social context Policy objective for access to insurance Fiscal tools Regulatory approach to facilitate access to insurance Regulatory tools Supervision / enforcement Market conditions Supervisory capacity 42 Note 2 Regulatory approaches to the promotion of inclusive insurance markets 1. What is a regulatory approach? 2. Which approaches exist? 3. What triggers a particular regulatory approach? 4. What is the impact of different approaches? 43 Regulatory approach continuum Regulatory approach continuum Public provision Approach Directive Approach Concessionary regime Nudge Approach State identifies risk to cover and outsources intermediation to private sector. Often substantial subsidies provided (fiscal exposure). State does not identify which risk should be covered and doesn’t make a financial contribution (no fiscal exposure). A reduction in the regulatory burden to enable lower risk products to be marketed to lower income clients at lower cost, whilst maintaining the normal regulatory burden for conventional insurance. Regulator does not consider it necessary to reduce the regulatory requirements for insurance provision to stimulate outreach into the low income market. It is considered sufficient to make policy declarations supporting access to insurance and to create some environmental enablers (e.g. lower cost, more accessible payment systems) The state makes certain elements of insurance mandatory but includes state subsidy. State determines which target market should be covered and sets requirements to private sector to cover these groups as a condition for being allowed to operate. Access to insurance by regulatory requirement The state is the primary driver in increasing access to insurance through a combination of direct subsidies, regulation and public decree. China India The concessions provided to reduce the regulatory burden encourages insurers to move downmarket as this is now a potentially commercially viable. South Africa Brazil Tanzania Philippines Mozambique Swaziland Zambia Nigeria Mongolia Ghana Ethiopia Colombia Uganda Lesotho Nepal Kenya 44 Note 2 Regulatory approaches to the promotion of inclusive insurance markets 1. What is a regulatory approach? 2. Which approaches exist? 3. What triggers a particular regulatory approach? 4. What is the impact of different approaches? 45 Regulatory approaches: triggers Approach Triggers Public policy Social goals Well developed insurance sector (distribution) Directive Strong development mandate Limited supervisory capacity High regulatory burden Market failures Deep insurance sector but limited distribution Concessionary Strong development mandate Sufficient supervisory capacity High regulatory burden Informality Limited breadth Market failures Nudge by design Strong development mandate Low regulatory burden Fear of systemic instability Well developed insurance sector Weak development mandate Limited supervisory capacity Nudge by default 46 Note 2 Regulatory approaches to the promotion of inclusive insurance markets 1. What is a regulatory approach? 2. Which approaches exist? 3. What triggers a particular regulatory approach? 4. What is the impact of different approaches? 47 What is the impact of regulatory approaches? Approaches Impacts observed Public Policy • Subsidies make it viable to operate where insurers would not otherwise have done so, but persistency rates after termination of subsidies can be low • Partial subsidies tend to be more effective, since culture of payment is developed rather than culture of entitlement • Triggers market provision if the state contracts private providers to deliver the services • Can also catalyse new products, for example health top-up products where public health insurance inadequate • Can increase barriers to entry if state provision crowds out private investment Directive approach • New clients are being served that would otherwise not be served, but targeting not always accurate and could be difficult to monitor • Can lead to suppliers ‘discovering’ viable and sustainable market opportunities Concessionary approach • Limited examples yet of successful formalisation, but observed in Philippines with substantial support and led by large provider • Concessions in distribution utilised before concessions in underwriting – especially mass channels Nudge • Institutions that are already serving the market strengthen their outreach • Markets do not respond to product restrictions without concessions • No visible impact where market is under-developed 48 Questions and discussion 49 www.access-to-insurance.org [email protected] (presenter) [email protected] (project director) 50