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Bank Marketing, AIC Disciplinary Website, Consumer Protection in Travel Insurance

Posted By Thom Young, March 28, 2017

The Banks Are Coming, the Banks Are Coming—They Never Went Away

Recent media reports (e.g., Insurance Business) have revealed that once again the marketing departments of our federal banks are flouting the rules for insurance sales. The problem seems cyclical. About every four or five years for as long as I can remember, the marketing managers unfamiliar with regulations governing their industry (maybe they’re a new crop of managers) begin their never-ending search for success by generating new revenue streams for their employers. (Maybe they review the revenue ledgers for the profit centre they are responsible for and wonder why there’s so little in the ones for insurance.)

Bank officers seem to receive little in the way of training on the regulatory responsibilities limiting their operations. While they may understand that banks cannot sell insurance from their branches, they don’t seem to understand that promoting the products of a subsidiary that sells insurance from their branches is the same as selling the insurance itself. In my own personal dealings with banks and lenders, I’ve often seen the offer of financing come with recommendations for life insurance and General insurance sourced by bank officers. When I do, I immediately notify the regulators, but most non-industry-related borrowers would not have any idea that they were being unduly influenced and directed by the inclusion of an insurance agent’s business card or even a quote for coverage when they are in the process of arranging financing.

Unlike the credit unions which are for the most part provincially regulated on marketing rules, the chartered banks are governed by the federal Bank Act. The Act provides a number of regulations that limit the ability of banks to use their market dominance and biased influence to compete unfairly in our business. The good lobbying efforts of our industry associations have been able to continue this limitation on the banks’ entry in our insurance market. Still, the banks seem to need to be reminded on regular intervals that they’re welcome to compete with us in selling insurance so long as they play the game the same way we do. Under Alberta insurance regulations, employees of a lending institution and many other professions cannot hold an agent’s licence if what they do can be used unfairly to influence the buying public into purchasing policies from them. Bankers are also restricted from holding an insurance licence by the Bank Act, which limits them on this point for the same reasons.

Those of us required to hold a licence to sell insurance are personally responsible for upholding the rules. The regulations require us to understand the rules, and our very jobs hinge on our compliance. The individuals involved in the banking business have no licences to enforce their compliance. Their employers are bound by the regulations but are rarely sanctioned for their employees’ violation of them. When they are caught in activities outside of the rules, their regulator most often sends them a letter to deal with the infraction and orders them to cease from further activity that is outside of the rules. When the federal Minister of Finance gives them formal notice, they usually comply, but sometimes they push back.

The banks pushed back a few of years ago when they were developing websites with hyperlinks to their insurance divisions. Their web pages advertising insurance products were indistinguishable from their banking pages. When consumer groups and our national association brought this conflation of the bank and the insurer to the attention of the Minister of Finance, the minister issued a notice that in his view they were violating the provisions in the Bank Act that prohibit the sale of insurance in their branches. Initially the Canadian Bankers Association began lobbying against this interpretation and attempted to justify the activity. The appeal didn’t go so well. The minister sent them a letter clarifying why they were wrong. Arguing a point of interpretation with the people who make the regulations rarely wins. Sometimes new regulations may be introduced that clarify what the government meant. Sometimes these new rules may seem punitive to the industry being regulated. Our industry can attest to such futile struggle in several examples over the years, not the least of which is the ongoing structure of the Alberta auto reforms introduced by the Government in Alberta over a decade ago.

The federal financial watchdog has now formally given the banks notice that they are under investigation for their marketing methods. The findings will no doubt show that the banks continue to press against the marketing service limits set out in several fair market regulations, not just the insurance ones. Telemarketing ignoring the Do Not Call List and violations of tied-selling rules for bank products seem to abound. These issues should not recur cyclically. Perhaps a couple of multi-million dollar fines might get the attention of the banks’ own in-house compliance people. Who knows if even that would have any effect. When you make billions of dollars, a million dollar fine would just be chump change, wouldn’t it?

The ongoing arguments about who can and how they can sell insurance products in Canada will continue. The banks invest millions of dollars in government advocacy and have whole departments in their organizations that develop strategy to get around rules and regulations that they see limiting their right to dominate any field in which they choose to compete. As with the stock brokerage investment business and before that the Trust business, they’ve been able to take over an entire industry and market sector completely with hardly any public notice. While some of our colleagues will argue the old laissez-faire point of view against regulations that limit or restrict access to markets, history repeatedly demonstrates that, without rules to ensure fair play, the marketplace does not play fair. This principle applies as much to those already in our business as it does to those who wish to expand their operations into it. Both the new entrants and the current players have to be watched closely as time and again insurers and large brokers try to dominate the market to the point that they can bypass competitive reality. Allowing anyone to do so is not going to benefit the consumer, the independent broker, or ultimately anyone. Market dominance destroys healthy competition by stifling the adaptation of price, service, and product to a competitive end. Without regulations to ensure fair play and proper enforcement of them, any marketplace won’t remain healthy or beneficial for long.

Transparency Is Important

The very public nature of our disciplinary matters has now become readily apparent in the Alberta Insurance Council’s new website. The public can now view the decisions of the disciplinary committees for the General Insurance Council, the Life Insurance Council, and the Adjusters Insurance Council, as well as the work of the appeal boards for each, at http://decisions.abcouncil.ab.ca/abic/en/nav.do.

As someone who has been involved in every one of the General Insurance Council decisions for the past four years, I like that the work being done is easily available for review. I think the very public and transparent record of these disciplinary matters will both encourage all licence holders to follow the rules properly and make the industry and public aware of the work being done to ensure that we serve the public properly!

If you are a DR for an insurance brokerage firm, I would encourage you to subscribe to this site for updates on who’s being disciplined for what. If your shop is large enough to have an HR person, I’d make certain that that person is subscribed too. You can subscribe to an RSS feed for email notifications of all new listings on the site at http://decisions.abcouncil.ab.ca/abic/en/l.do.

Speaking about the Regulations—Better Consumer Protection Is Needed

Ultimately, government regulations are enacted only to benefit the public. Whether the regulations are about the way insurance coverage is interpreted and adjudicated for losses or about keeping the market for these products competitive for the consumer, they’re all about the customer. The main lobbying point from the various associations representing all the participants in our industry is that making rules that benefit their operations will provide a better outcome for the public.

One issue that seems to cause recurring problems is distance from a licensed insurance agent. The further the insurance sale gets from the sales intermediary who is licensed and required by the regulations to have a standard of knowledge and professional conduct, the worse the outcome seems to be for the customer. The problem arises with many different kinds of insurance products. Take creditor life and disability insurance for example or equipment warranty coverage offered by equipment dealers. Travel insurance is another example. A report produced by insurance regulators has determined that a good number of travel insurance companies in Canada are not treating their customers fairly. Have any of you had the displeasure of reviewing one of these wordings for your clients after the adjuster tells them they’re not covered? In my experience with several situations, reviewing the wordings is complicated and discussing the coverage with the insurers confusing even for an insurance professional. The insured often times gives little thought to what the coverage is until such time as when a claim arises.

bitterness of poor quality remains long after the sweetness of low price is forgottenThe consumer’s assumption of comprehensive coverage seems to prevail as the seller puts little emphasis on pointing out the limitations of coverage and the seller’s knowledge of the product rarely amounts to little more than understanding where the insured is to sign on the application. Such deficiencies might be acceptable when the product is an extended warranty on a $135 ink jet printer but clearly not when a travel insurer may be adjudicating a US$50,000 hospital bill claim. This client might not have travelled to where the medical condition occurred had this client been aware that a claim arising from a condition that is already being treated may not be covered. Alternatively, this client might have been offered a product with a higher premium that was commensurate with the risk exposure for this client’s situation.

The real issue with travel insurance from an insurance perspective is that it is “post claim” underwritten. Few questions are asked in the application stage. The insurer thoroughly reviews the risk and makes a qualifying assessment only when a claim is made. Only then is the question asked, “Would we have insured this person for this risk?” If the answer is “no,” the applicants are left on their own to deal with the loss and not even given the basic assistance of adjudication by an insurer that often reduces the cost of a claim in the U.S. by more than half of the uninsured billings. Other than a few absolutes that limit or void coverage such as age and pronounced medical conditions, little in the process of obtaining travel insurance provides the applicants with the knowledge necessary to comprehend whether the policy actually provides the protection they expect it does. Involving an agent with an Accident and Sickness licence in the process provides a good chance that the client understands what a preexisting condition may be and how it is defined. Unfortunately, these contracts are more frequently arranged by travel agents or even completed online by the individual applicant dealing directly with the insurer than they are being completed with the assistance of an insurance professional. I recall reviewing a declined claim for an 83-year-old lady who bought a policy for a trip to Florida only to find that after a medical event leaving her with a $15,000 bill that the company she bought the coverage from didn’t insure anyone over the age of 65. She was even more confused because she had been buying the coverage from the same people for 15 years.

Travel insurance is a lucrative business. Analysis of the returns on this product for the insurers show it to be a real money maker. More checks and balances seem needed in the process to protect the consumer better. Does anyone have different thoughts or some suggestions as to how to address this problem? Please send me a note!

In Conclusion

I was out last week for my first Canadian ride on a motorcycle this year. The roads are covered in sand and gravel, wet, and in shady spots even icy. With nearly 60 years of riding experience, I’m well aware of the technical issues of road conditions and am able to navigate these hazards without too much difficulty. The road conditions are a given, but the main hazard for bikers old and new are the people driving the four wheelers. Particularly in spring, they’re not used to motorcycles on the road and often enter the roadways or change lanes without consideration of the people on motorcycles. Our bikes are small, hard to see, and quicker than many expect them to be. It’s hard to judge how fast we’re coming at you when you’re making a left turn, and we fit too well into the blind spot beside your car. While we do our best defensively to avoid getting in your way, if you are not watching for us we can’t always be quick enough to avoid you. The first statement given by the driver of a car when explaining an accident with a motorcyclist is always “I didn’t see him.” The truth more properly told is that the driver wasn’t looking. As our spring continues to unfold into our brief summer, please give us a thought while driving, and take a little extra care looking for us! We’re not all wheelie popping head bangers on crotch rockets ripping up the roads. Some of us are quite harmless old papas just out enjoying a leisurely ride on a sunny spring day. My grandchildren will thank you if you watch out for me in your travels.

Are you getting ready for Convention? I’m excited this year and will be presenting an interesting topic for discussion at the Broker Town Hall. If you haven’t got yourself booked in yet, get yourself on the IBAA website and do it now!

Keep those ideas for discussion coming. My private email address is thom.young@landy.ca and you can get me on twitter @Thomcat04. Some of you have found me on LinkedIn and Facebook too.

The opinions expressed in this blog are not necessarily those of IBAA.
Comment on this post below or email Thom Young privately. Thom also encourages suggestions for topics.

 

Tags:  Alberta Insurance Council  Bank Act  banks marketing insurance  disciplinary website  insurance licence  motorcycle  travel insurance 

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Motor Vehicle Renewal Notice Changes, Self-Driving Cars, Crazy Laws

Posted By Thom Young (Full first name: Thomas Clifford John), April 12, 2016

Changes in the Way the Government Communicates with Us

It’s funny how bureaucrats think. The resolution of a problem often seems to ignore the effect of the action that resolves it. Political considerations seem to be reviewed with a self-induced euphoria about the positive effects the action will have. When the change turns out to be unpopular or unworkable, it’s rare for anyone to own the reason for it.The changes to motor vehicle license renewal seem to be a case in point.

The folks who make the policy at Service Alberta (that’s the department that manages things like motor vehicle license registrations and renewals) have determined that they will save postage and handling costs if they stop mailing renewal notices to the public for their license plate renewals, and the public will be so much happier to receive their renewal notice via email instead of by mail. Now, if I was introducing a service like this to my customers, I think I’d have a plan in place to advise them of this change on their last renewal, give them the opportunity to update an email contact listing, and require them to visit an interactive website in order to open such an account with me. Then I’d send out a confirmation reminder via email perhaps 90 days or so before the expiry requesting confirmation of the new arrangement. If I didn’t get a reply, I’d send them the old paper-style renewal again and remind them of the need to register their email address before the next renewal. After several cycles that way, then I’d actually call them to get things organized or determine that they don’t have the capability of communicating this way and put them in a special category for paper communication on the next renewal. In our business, we’re interested in keeping these people happy with the way we are dealing with them so they don’t seek better service from our competitors. The government doesn’t really have any competitors, so the incentive to care isn’t so great.

Failing to care is a sure-fire recipe for annoying everyone. There’s really no one to complain to about this change in service either. You can go yell at your registry agents, but they don’t have anything to do with setting the policy and, in fact, have already fought with the bureaucrats to get a workable system in place for these renewals. Those in charge think it’s all going to work out fine. I have my doubts.

As insurance brokers, our services to our customers often do not coincide with the motor vehicle license renewal cycle. People who move to our province need to get insurance before they can register their vehicles. Their policies are effective on their first registration. Since the motor vehicle license renewal cycle is based on alphabetized names, it will not likely coincide with the insurance renewal. Nonetheless, we could provide a helpful service to our clients by letting them know about this new government policy. Here’s the nuts and bolts of it:

Effective April 1, 2016 (no joke here), renewal notices will no longer be processed by regular mail. If you haven’t registered for an email advisory with the government directly or with one of the registry agents that offer this service (not all do), then you’d better make a calendar reminder somewhere to ensure that you renew your vehicle registration prior to its expiry. There is an exception: if you are over 70 years of age or have a disability, you will receive a mailed renewal notice until next April when everyone will be treated the same. I’m not sure how they are tracking disabled people, but they do have a way to track age. If you don’t fall into either of the aforementioned categories and don’t feel a calendar reminder will be effective, sign up for an email reminder using one of the following three methods.

The latter allows you to choose email, text, or both email and text messages.

Time will tell if this new “service” brought to you by the Government of Alberta is a success or if it fails to meet the needs of the Alberta public. No doubt the government will save a substantial amount on postage, but those who fail to renew their registration on time will produce additional general revenues for the government. The fine for driving a vehicle with an expired license plate tag is $230 dollars. Worse still, the officer has discretion to impound your car until you produce the valid registration for it. In addition to being stranded on the side of the road, the cost does not stop at the fine. Depending on where you are, about $200 more could be added to the cost for the tow and impound fees plus the taxi ride to the registry and the impound lot. It’s not small potatoes when you add it all up. If you are caught with expired registration while getting a ticket for something else, you can find yourself quickly having a $1000-day with zero entertainment value.

One of my favourite quotations is “I’m from the government, and I’m here to help you!” Good luck with that!

Self-Driving Cars

I keep hearing all these reports about the challenges of insuring self-driving automobiles. What’s the fuss about? The owner of the automobile is responsible to ensure the vehicle and its operation regardless of who the driver is. The SPF 1 anticipates that the driver will hold a “license,” or specifically, that the owner believes the driver does when care and custody of the vehicle is given over. The driver is also expected to have a “legal capacity” and not be impaired. The only challenges to insure vehicles driven by computers, then, seem to be that the computer must have a license and the insurer must be willing to assume the risk. Licensing is mostly a regulatory issue. The experience of the computer programs that will be driving these cars could be easily determined from the computer records of these programs in operation. In general, I think that experience will show the computers are much safer drivers with reduced losses, but I might be having a bout of wishful thinking here.

If the computers produce the substantially better loss experience they are predicted to, then the end result will be much lower payouts for insured losses that will have a positive effect on the business, won’t it? If overall claims decline, then everyone benefits.

Still I’m confused about all the hype about how to insure these risks. I’m quite certain that insurers will lineup to participate in that pool.

Some Crazy Laws

In Florida, if you tie your elephant up at a parking meter, you have to put money in the meter or you’ll be fined. Here are some other crazy rules and regulations that actually are laws on the books:

16 crazy rules
  1. In England all Hackney vehicles (taxi cabs) must have a bale of hay and a bag of oats with them at all times.
  2. All Danish vehicle operators must check under the car before they start it to be sure there’s no one underneath.
  3. Eating or drinking anything while driving a motor vehicle in Cyprus is against the law!
  4. In Luxembourg all vehicles must have windshield wipers even if they don’t have a windshield.
  5. In Russia you can be fined for driving a dirty car!
  6. In Germany it is illegal to run out of gas while driving on an autobahn!
  7. In Spain you are required to have an extra pair of glasses in your car if you wear glasses!
  8. In some cities in Spain you can only park on the odd numbered side of the road on odd days and the even side of the road on even days. Failure to comply will see your car towed.
  9. In Scandinavian countries you are required to have headlights on at all times.
  10. In Estonia it is required that you have two wheel chocks in your automobile at all times.
  11. In Turkey you are required to have a safety kit in your car that has a fire extinguisher, reflective triangle and first aid kit, you must show this to the police when stopped or you will be fined.
  12. In France all vehicle have to have a Breathalyzer in them and there is a fine of 11 euros if you can’t show it to the police when asked.
  13. All cars on the road in Serbia must have a tow bar and a 3 meter tow rope.
  14. In Manilla you are not allowed to drive on Mondays if your license plate ends in 1 or 2.
  15. In Japan if you splash a pedestrian driving through a puddle you will be fined $65.
  16. In Singapore it’s against the law for a driver to come within 50 meters of a pedestrian but pedestrians aren’t allowed to walk on the roads either.
    (http://www.huffingtonpost.com/2013/12/16/the-50-most-insane-driving-laws_n_4452693.html)

Never underestimate the ability of legislators to come up with silly rules and regulations to “protect” you. Remember my favourite quotation, “I’m from the government, and I’m here to help you.”

In Closing

I trust everyone is enjoying this unseasonal weather. It seems too early to declare that spring has sprung, but tell that to the trees that are budding out and tulips pushing through the garden. All the same, don’t count Mother Nature out. She’s sure to toss another winter storm at us before summer comes. As you’re out enjoying this balmy weather, please look twice for motorcycles. The life you save may be mine!

The opinions expressed in this blog are not necessarily those of IBAA.
Comment on this post below or email Thom Young privately. Thom also encourages suggestions for topics.

 

Tags:  autonomous cars  motor vehicle license renewal  motorcycle  self-driving cars  Service Alberta  SPF 1  vehicle registration 

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Motorcycle Awareness, Organ Donor Initiatives, Overland Flood Coverage

Posted By Thom Young, April 21, 2015
Updated: April 20, 2015

Motorcycle Awareness

With our spring weather, motorcycles are back on the road again, and people need to be looking for bikes. The most common injury to motorcyclists comes from vehicles turning in front of them, either making an unsafe left turn or failing to yield the right of way to a motorcycle by entering the highway in front of them. Virtually all of the drivers who cause these accidents claim they didn’t see the motorcyclist. In truth though, they weren’t looking. Often, they fail to judge the speed of a motorcycle approaching them because of either inexperience or indifference. Many state after the fact that they believed the motorcyclist was travelling at excessive speed. I’ll concede that they may be right on the speed issue once in a while, but, in reality, analysis of the impact usually exonerates the motorcyclist. Unfortunately though, whether right or wrong, the motorcyclist and passenger are always the losers in any motor vehicle accident. Please watch out for motorcycles on the roadways. Double check when making that left turn, and give extra space to allow them to pass before pulling out on the highway. In particular, if you see a large black Harley going by with a couple of happy people on it, wave. I’ll be sure to wave back!

Speaking of motorcycle safety, let’s not forget the extra precautions that we as motorcyclists need to take to ensure our own safety and the advice we should be giving our clients on this issue as well. IBC publishes a number of very good handouts on insurance matters, and all insurance brokers should remember their role as educators and advisers to their clients on preventing loss and ensuring their safety.

IBC's Top 10 Tips for a Safe Motorcycle Ride

    IBC Motorcycle Tips
  1. Drive what you can control. Often, people buy motorcycles that are too powerful for them to handle. Ask your dealer if you can test drive the bike before you buy it.

  2. Take a safety course. Be aware of your limits on a motorcycle. What would happen if you had to quickly avoid an incident?

  3. Ride according to weather and road conditions. Check the forecast and keep your eyes on the road ahead.

  4. Wear a DOT (Department of Transportation) approved helmet.  Choose the helmet best suited for how you ride, and replace your helmet every five years.

  5. Wear clothing that will protect you in a fall. Heavy denim or leather jackets and pants aren't just stylish; they help prevent nasty cuts and burns if you fall.

  6. Stay focused on the road. The cold reality is that motorcyclists are 30 times more likely to die in a collision than people in a car, according to the Insurance Institute for Highway Safety.

  7. Always be seen. Assume car drivers can't see you, so leave them plenty of room. Also, wear clothing or reflective materials that allow you to be seen.

  8. Ride in the proper position in the lane. Know where you should be positioned in the lane and never drive along the middle of the lane where there is oil build up from cars.

  9. Practise riding with others. When riding as a group form a staggered pattern and establish hand signals that all of the riders understand.

  10. Stop frequently. Being rested will help you focus on the roads.

Download IBC’s Motorcycle Tips poster.


Riders, be careful out there. The number one thing you need to do is drive defensively. On any motorcycle, you have maneuverability and visibility advantages, but they won’t save you unless you are keeping a lookout for what the other guy is doing. I couldn’t give any better advice on this issue! In my experience, it usually doesn’t matter who is at fault in an accident involving a motorcycle: the motorcyclist always loses.

Organ Donor Initiatives Revisited

I received a whole bunch of emails thanking me for making this topic an issue for discussion. My superficial review of what’s going on was criticized as well because I didn’t cover the topic in its entirety. In the last issue, I barely touched on the whole registry initiative that is underway, so here is the circular and the form that Alberta health sent to registries. You can complete the form yourself and make the brochure available in your insurance offices as well. Let’s make this important issue a game changer.

Alberta Organ and Tissue Donation Registry Brochure and Form

Overland Flood Coverage

I received a briefing on this new initiative of Aviva. The program looks very good, and I’m very excited about its introduction in our province. Brokers need to get behind it for two reasons: one is it’s good for our clients, and the other is the way it’s being rolled out. You have huge E&O exposure if you fail to provide information on it to your clients. Even existing Aviva clients will need to be presented an option midterm to ensure that they have been given notice that this coverage is available. Any opportunity to contact your client about anything is a huge opportunity to give that value-added service that others aren’t providing. You need to get a plan together. Write your homeowner clients a letter explaining what’s available and how they can get it. They may choose to wait until the renewal or to stay with what they have, but, regardless, we have to let them know. The letter needs to be followed up with a phone call and notes on the resulting discussions about the coverage. If you explain the coverage properly, the client declines it, and you fully document the interaction, there will be no coming back at you if there’s an overland flood coverage shortfall. Further, this contact will give you a wonderful opportunity to cross sell your other insurance products to your clients.

Now that the word is out, we’ll need to listen carefully to the competitive response by other insurers. One hopes that a uniform approach to this coverage by the major players will keep our marketplace level and not disrupt our clients so badly that our industry comes into disrepute on account of it. I noticed a news article on TV this week which focused on the dilemma of a homeowner who had three weather-related losses in the past five years and was advised that the insurer would not be willing to offer a renewal if any further weather-related losses occurred. The gist of the discussion was that coverage refusal was unfair. Well, it may be unfortunate but not unfair. We as an industry need to continue to educate our clients on the issues before them. Insurance remains a vehicle to share the risk of sudden and unforeseeable events. If a loss becomes a routine occurrence, companies will not want to share that risk unless the premiums are high enough to cover the losses in time. The perception that making money is bad and that our industry focuses on unreasonable expectations of returns ahead of the needs of the public is unfortunate. The premiums produce the money to pay the claims. If the claims exceed the premiums, then the premiums go up. It’s not really rocket science.

Negative selection due to these new coverages may occur, and we may well find the public pushing back, especially where a group is redlined from the coverage on account of an area’s high risk. At some point, sharing these excessively high risks may have to come about through government intervention in the market that mandates basic coverages supported by a government-funded risk sharing pool. Perhaps a facility for facultative underwriting of residential risk may be needed. Time will tell my friends, and it is an exciting time to be in our business!
 

In Closing

It’s nice to be back in Alberta for a while—a little windy for my liking, but the weather is temperate for this time of year. I have no illusions that I’m home scot-free of some inclement weather—at least one big spring snow storm. As dry as it is in the south, precipitation will be welcome no matter how it comes. Most of the grain crops are sown. If Mother Nature cooperates, the harvest should be early this year.

The opinions expressed in this blog are not necessarily those of IBAA.
Comment on this post below or email Thom Young privately. Thom also encourages suggestions for topics.

Tags:  motorcycle  organ donor  overland flood insurance 

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