conduct of business returns (“cbr’s”) · page 1 of 55 conduct of business returns...

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Page 1 of 55 Conduct of Business Returns (“CBR’s”) Revised Categorisation, questions and reporting levels Response to industry comments EXECUTIVE 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 2013. 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, 2015. 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.

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Page 1 of 55

Conduct of Business Returns (“CBR’s”)

Revised Categorisation, questions and reporting levels

Response to industry comments

EXECUTIVE 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 insurers1.

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 2013. 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, 2015. 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.

CBR’s – Response to industry comments

Page 2 of 55

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.

CBR’s – Response to industry comments

Page 3 of 55

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, 2015.

1. 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.

CBR’s – Response to industry comments

Page 4 of 55

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 [email protected] on or before 18 March 2016.

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 2016.

Page 5 of 55

4. REPORTING LEVELS 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.

4.1. 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.

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

1. 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

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

evacuation or transport

Underwritten on a group

basis

Non-medical expense

cover as a result of

hospitalisation

Frail care

HIV, Aids, tuberculosis

and malaria testing

and treatment

Medical emergency

evacuation or transport

c. Individual Disability

– lump sum

Individually risk rated Own occupation

disability

Own/similar

occupation disability

Total disability

Functional Impairment

Underwritten on a group

basis

Own occupation

disability

Own/similar

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

occupation disability

Total disability

Functional Impairment

d. Individual Disability

– recurring

payment

Individually risk rated Own occupation

disability

Own/similar

occupation disability

Total disability

Functional Impairment

Underwritten on a group

basis

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

CBR’s – Response to industry comments

Page 8 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 9 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

2.

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

CBR’s – Response to industry comments

Page 10 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 11 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

hospitalisation

Frail care

HIV, Aids, tuberculosis

and malaria testing

and treatment

Medical emergency

evacuation or transport

Retrenchment

Other

Optional Death;

Disability (lump sum); Own occupation

disability

Own/similar

occupation disability

Total disability

Functional Impairment

Disability (recurring); Own occupation

disability

Own/similar

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 13 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

and treatment

Medical emergency

evacuation or transport

Retrenchment

Other

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

CBR’s – Response to industry comments

Page 14 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 15 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

Other

Optional 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

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 17 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

group basis

b. Group

5. LIFE ANNUITIES a. With Discretionary

Participation

features

b. Other

6. INDIVIDUAL

INVESTMENT

a. With Discretionary

Participation

features

Fund member policies Retirement annuities

Preservation funds

Endowment policies

Other

b. Other Fund member policies Retirement annuities

Preservation funds

Endowment policies

Other

7. FUND INVESTMENT a. With Discretionary

Participation

features

CBR’s – Response to industry comments

Page 18 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 20 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – Response to industry comments

Page 21 of 55

LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5

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

CBR’s – response to industry comments

Page 22 of 55

4.2 QUESTIONS AND REPORTING LEVEL FOR LIFE INSURERS

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1 BUSINESS COMPOSITION

1.1 State the number of policies in force at the end of the quarter.

X

1.2 State the number of benefits in force at the end of the quarter.

X X

1.3 State the total gross written premium for all policies in force at the end of the quarter.

X

1.4 State the number of new policies issued in the quarter.

X

1.5 State the number of new benefits issued in the quarter.

X X

1.6 State the total gross written premium for all new policies issued in the quarter.

X

1.7 State the number of new policies issued in the quarter as per the income group breakdown below:

X

1.7.1 Low income; X

1.7.2 Middle income; X

1.7.3 Upper income. X

1.8 State the number of new policies issued in the quarter as per the breakdown below:

X

1.8.1 Direct marketing via telesales/call centre of the insurer;

X

1.8.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.8.3 Direct marketing via telesales/call centres of any other third party;

X

1.8.4 Direct marketing via internet; X

1.8.5 Marketing via aggregator and/or lead generator;

X

1.8.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.8.7 Face-to-face by insurer's juristic representatives;

X

1.8.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

CBR’s – Response to industry comments

Page 23 of 55

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.8.9 Other (please specify). X

1.9 State the gross written premium for new policies issued in the quarter as per the breakdown below:

X

1.9.1 Direct marketing via telesales/call centre of the insurer;

X

1.9.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.9.3 Direct marketing via telesales/call centres of any other third party;

X

1.9.4 Direct marketing via internet; X

1.9.5 Marketing via aggregator and/or lead aggregators;

X

1.9.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.9.7 Face-to-face by insurer's juristic representatives;

X

1.9.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.9.9 Other (please specify). X

1.10

State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the breakdown below:

X

1.10.1 Direct marketing via telesales/call centre of the insurer;

X

1.10.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.10.3 Direct marketing via telesales/call centres of any other third party;

X

1.10.4 Direct marketing via internet; X

1.10.5 Marketing via aggregator and/or lead generator;

X

1.10.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.10.7 Face-to-face by insurer's juristic representatives;

X

CBR’s – Response to industry comments

Page 24 of 55

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.10.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.10.9 Other (please specify). X

1.11

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:

X

1.11.1 Low income; X

1.11.2 Middle income; X

1.11.3 Upper income. X

1.12

State the number of policies cancelled on the instruction of the policyholder (excluding cancelled in “cooling off period”) during the quarter.

X

1.13 State the number of policies cancelled on the instruction of the insurer during the quarter.

X

1.14 State the number of policies which were cancelled in terms of “cooling off” provisions during the quarter

X

1.15 State the number of policies less than 12 months old that lapsed in the quarter as per the breakdown below:

X

1.15.1 Direct marketing via telesales/call centre of the insurer;

X

1.15.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.15.3 Direct marketing via telesales/call centres of any other third party;

X

1.15.4 Direct marketing via internet; X

1.15.5 Marketing via aggregator and/or lead generator;

X

1.15.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.15.7 Face-to-face by insurer's juristic representatives;

X

CBR’s – Response to industry comments

Page 25 of 55

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.15.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.15.9 Other (please specify). X

1.16 State the number of policies less than 12 months old that lapsed in the quarter as per the income group breakdown below:

X

1.16.1 Low income; X

1.16.2 Middle income; X

1.16.3 Upper income. X

1.17 State the number of policies between 12 and 24 months old that lapsed in the quarter.

X

1.18

State the number of policies between 12 and 24 months old that lapsed in the quarter as per the income group breakdown below:

X

1.18.1 Low income; X

1.18.2 Middle income; X

1.18.3 Upper income. X

1.19 State the number of policies older than 24 months that lapsed in the quarter.

X

1.20 State the number of policies older than 24 months that lapsed in the quarter as per the income group breakdown below:

X

1.20.1 Low income; X

1.20.2 Middle income; X

1.20.3 Upper income. X

1.21 State the number of benefits that were cancelled by the policyholder in the quarter.

X X

1.22 State the number of policies less than 12 months old made paid-up in the quarter as per the breakdown below:

X

1.22.1 Direct marketing via telesales/call centre of the insurer;

X

1.22.2 Direct marketing via telesales/call centre of affinity schemes;

X

CBR’s – Response to industry comments

Page 26 of 55

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.22.3 Direct marketing via telesales/call centres of any other third party;

X

1.22.4 Direct marketing via internet; X

1.22.5 Marketing via aggregator and/or lead generator;

X

1.22.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.22.7 Face-to-face by insurer's juristic representatives;

X

1.22.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.22.9 Other (please specify). X

1.23 State the number of policies less than 12 months old made paid-up in the quarter as per the income group breakdown below:

X

1.23.1 Low income; X

1.23.2 Middle income; X

1.23.3 Upper income. X

1.24 State the number of policies between 12 and 24 months old made paid-up in the quarter.

X

1.25

State the number of policies between 12 and 24 months old made paid-up in the quarter as per the income group breakdown below:

X

1.25.1 Low income; X

1.25.2 Middle income; X

1.25.3 Upper income. X

1.26 State the number of policies older than 24 months made paid-up in the quarter.

X

1.27 State the number of policies older than 24 months made paid-up in the quarter as per the income group breakdown below:

X

1.27.1 Low income; X

1.27.2 Middle income; X

1.27.3 Upper income. X

CBR’s – Response to industry comments

Page 27 of 55

LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.28 State the number of policies surrendered in the quarter as per the breakdown below:

X

1.28.1 Direct marketing via telesales/call centre of the insurer;

X

1.28.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.28.3 Direct marketing via telesales/call centres of any other third party;

X

1.28.4 Direct marketing via internet; X

1.28.5 Marketing via aggregator and/or lead generator;

X

1.28.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.28.7 Face-to-face by insurer's juristic representatives;

X

1.28.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.28.9 Other (please specify). X

1.29

State the number of policies surrendered, as indicated above, which was due to replacement in the quarter as per the breakdown below:

X

1.29.1 Direct marketing via telesales/call centre of the insurer;

X

1.29.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.29.3 Direct marketing via telesales/call centres of any other third party;

X

1.29.4 Direct marketing via internet; X

1.29.5 Marketing via aggregator and/or lead generator;

X

1.29.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.29.7 Face-to-face by insurer's juristic representatives;

X

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.29.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.29.9 Other (please specify). X

1.30 State the number of policies surrendered in the quarter as per the income group breakdown below:

X

1.30.1 Low income; X

1.30.2 Middle income; X

1.30.3 Upper income. X

1.31 State the number of policies transferred in the quarter as per the breakdown below:

X

1.31.1 Direct marketing via telesales/call centre of the insurer;

X

1.31.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.31.3 Direct marketing via telesales/call centres of any other third party;

X

1.31.4 Direct marketing via internet; X

1.31.5 Marketing via aggregator and/or lead generator;

X

1.31.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.31.7 Face-to-face by insurer's juristic representatives;

X

1.31.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.31.9 Other (please specify). X

1.32 State the number of policies transferred in the quarter as per the income group breakdown below:

X

1.32.1 Low income; X

1.32.2 Middle income; X

1.32.3 Upper income. X

1.33 State the number of new policies, which were replacement policies, issued in the quarter, as per the breakdown below:

X

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

1.33.1 Direct marketing via telesales/call centre of the insurer;

X

1.33.2 Direct marketing via telesales/call centre of affinity schemes;

X

1.33.3 Direct marketing via telesales/call centres of any other third party;

X

1.33.4 Direct marketing via internet; X

1.33.5 Marketing via aggregator and/or lead generator;

X

1.33.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

1.33.7 Face-to-face by insurer's juristic representatives;

X

1.33.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.33.9 Other (please specify). X

2 DISTRIBUTION AND BINDER COSTS

2.1 Please state the total commission paid in the quarter as per the breakdown below:

X

2.1.1 Direct marketing via telesales/call centre of the insurer;

X

2.1.2 Direct marketing via telesales/call centre of affinity schemes;

X

2.1.3 Direct marketing via telesales/call centres of any other third party;

X

2.1.4 Direct marketing via internet; X

2.1.5 Marketing via aggregator and/or lead generator;

X

2.1.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

2.1.7 Face-to-face by insurer's juristic representatives;

X

2.1.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

2.1.9 Other (please specify). X

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

2.2 Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below:

X

2.2.1 Enter into, vary or renew a policy; X

2.2.2 Determining wording of a policy; X

2.2.3 Determining premiums under a policy; X

2.2.4 Determining the value of benefits under a policy;

X

2.2.5 Settling a claim under a policy. X

2.3

Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.

X

3 CLAIMS MANAGEMENT

3.1 State the number of claims that were reported to the insurer in the quarter.

X X

3.2 State the value of claims that were reported in the quarter.

X X

3.3 State the number of claims that were paid in the quarter.

X X

3.4 State the value of claims that were paid in the quarter.

X X

3.5 State the number of claims that were repudiated in the quarter.

X X

3.6 State the value of claims that were repudiated in the quarter.

X X

3.7 State the number of claims outstanding at the end of the quarter.

X X

3.8 State the value of claims outstanding at the end of the quarter.

X X

4 COMPLAINTS HANDLING

4.1 State the number of complaints received in the quarter as per the breakdown below:

4.1.1

Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits);

X

4.1.2 Complaints relating to product performance (including but not limited to investment

X

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

performance);

4.1.3 Complaints relating to product accessibility, changes or switches (including termination charges);

X

4.1.4 Complaints relating to claims, in relation to: X

4.1.4.1 Claim handling process; X

4.1.4.2 Claims repudiated. X

5 ADD-ON/RIDER BENEFITS

5.1 Do you offer any of the following benefits as add-on/rider benefits to the policies? X

5.1.1 Retrenchment; X

5.1.2 Emergency evacuation/transport; X

5.1.3 Legal Expenses; X

5.1.4 Cash back/No claim; X

5.1.5 Loyalty benefit as part of product; X

5.1.6 Loyalty benefit as part of separate program;

X

5.1.7 Other (please specify). X

5.2 State the number of policies with the add-on/rider benefits as per the breakdown below:

X

5.2.1 Retrenchment; X

5.2.2 Emergency evacuation/transport; X

5.2.3 Legal Expenses; X

5.2.4 Cash back/No claim; X

5.2.5 Loyalty benefit as part of product; X

5.2.6 Loyalty benefit as part of separate program;

X

5.2.7 Other (please specify). X

GENERAL SHEET

1 PAYMENTS

1.1 Please state the total outsourcing fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.

X

1.2 Please state the total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown

X

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

below:

1.2.1 Television; X

1.2.2 Radio; X

1.2.3 Print media; X

1.2.4 Social media; X

1.2.5 Other. X

1.3

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:

1.3.1 Television; X

1.3.2 Radio; X

1.3.3 Print media; X

1.3.4 Social media; X

1.3.5 Other. X

2 COMPLAINTS

2.1 State the number of all complaints received in the quarter.

X

2.2 State the number of complaints received in the quarter as per the breakdown below:

X

2.2.1

Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures);

X

2.2.2 Complaints relating to service; X

2.2.3 Complaints relating to advice in respect of each of the following distribution channels:

X

2.2.3.1 Insurer's "face-to-face" representatives;

X

2.2.3.2 Insurer's call centre representatives;

X

2.2.3.3 Independent FSP's X

2.2.3.4 Other X

2.2.4 Complaints relating to complaints handling process;

X

2.2.5 Other complaints. X

2.3 State the number of all complaints finalised in favour of the policyholder in the quarter.

X

2.4 State the number of all complaints X

CBR’s – Response to industry comments

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LIFE INSURERS

LEVEL OF QUESTIONS

SUB

LEVEL SUB

LEVEL SUB

LEVEL

2 4 5

outstanding at the end of the quarter.

CBR’s – response to industry comments

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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.

LEVEL 1 LEVEL 2 LEVEL 3

1. MOTOR a. Personal lines Comprehensive;

3rd Party;

3rd Party, fire & theft;

Other

b. Commercial lines Comprehensive;

3rd Party;

3rd Party, fire & theft;

Other

2. PROPERTY a. Personal lines Contents;

Specified items;

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LEVEL 1 LEVEL 2 LEVEL 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;

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LEVEL 1 LEVEL 2 LEVEL 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 EXPENSE a. Personal lines

b. Commercial lines

10. LIABILITY Directors and officers

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LEVEL 1 LEVEL 2 LEVEL 3

Employer liability

Product liability

Professional indemnity

Public liability

Aviation

Engineering

Marine

Motor

Rail

Transport

Personal

Other

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LEVEL 1 LEVEL 2 LEVEL 3

11. 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

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LEVEL 1 LEVEL 2 LEVEL 3

c. Personal lines - Other

d. Commercial lines - Mandatory Accident & Health;

Motor;

Property: Specified items;

Property: Building structure;

Credit Shortfall;

Other

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LEVEL 1 LEVEL 2 LEVEL 3

e. Commercial lines - Optional Accident & Health;

Motor;

Property: Specified items;

Property: Building structure;

Credit Shortfall;

Other

f. Commercial lines - Other

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LEVEL 1 LEVEL 2 LEVEL 3

12. 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);

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 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

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LEVEL 1 LEVEL 2 LEVEL 3

15. 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;

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 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: 3rd Party;

Motor: 3rd Party, fire & theft;

Motor: Other;

Property: Contents;

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 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: 3rd Party;

Motor: 3rd Party, fire & theft;

Motor: Other;

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 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;

CBR’s – Response to industry comments

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LEVEL 1 LEVEL 2 LEVEL 3

Liability: Professional indemnity;

Liability: Public liability;

Liability: Other;

A&H: Personal accident;

A&H: Health event other than accident;

Miscellaneous: Warranty;

Miscellaneous: Other.

CBR’s – response to industry comments

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4.4 QUESTIONS AND REPORTING LEVEL FOR NON-LIFE INSURERS

NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

1 BUSINESS COMPOSITION

1.1 State the number of policies in force at the end of the quarter. X

1.2 State the number of cover types in force at the end of the quarter.

X

1.3 State the total gross written premium for all policies in force at the end of the quarter. X

1.4 State the number of new policies issued in the quarter. X

1.5 State the number of new cover types issued in the quarter.

X

1.6 State the total gross written premium for all new policies issued in the quarter. X

1.7 State the number of policies issued in the quarter as per the income group breakdown below:

X

1.7.1 Low income; X

1.7.2 Middle income; X

1.7.3 Upper income. X

1.8 State the number of new policies issued in the quarter as per the breakdown below: X

1.8.1 Direct marketing via telesales/call centre of the insurer; X

1.8.2 Direct marketing via telesales/call centre of affinity schemes; X

1.8.3 Direct marketing via telesales/call centres of any other third party; X

1.8.4 Direct marketing via internet; X

1.8.5 Marketing via aggregator and/or lead generator; X

1.8.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X

1.8.7 Face-to-face by insurer's juristic representatives; X

1.8.8

Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

1.8.9 Other (please specify). X

1.9

State the gross written premium for new policies issued in the quarter as per the breakdown below:

X

1.9.1 Direct marketing via telesales/call centre of the insurer; X

1.9.2 Direct marketing via telesales/call centre of affinity schemes; X

1.9.3 Direct marketing via telesales/call centres of any other third party; X

1.9.4 Direct marketing via internet; X

1.9.5 Marketing via aggregator and/or lead generator; X

1.9.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X

1.9.7 Face-to-face by insurer's juristic representatives; X

1.9.8

Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.9.9 Other (please specify). X

1.10

State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the breakdown below:

X

1.10.1 Direct marketing via telesales/call centre of the insurer; X

1.10.2 Direct marketing via telesales/call centre of affinity schemes; X

1.10.3 Direct marketing via telesales/call centres of any other third party; X

1.10.4 Direct marketing via internet; X

1.10.5 Marketing via aggregator and/or lead generator; X

1.10.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X

1.10.7 Face-to-face by insurer's juristic representatives; X

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

1.10.8

Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.10.9 Other (please specify). X

1.11

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:

X

1.11.1 Low income; X

1.11.2 Middle income; X

1.11.3 Upper income. X

1.12 State the number of policies cancelled by the policyholder in the quarter. X

1.13 State the number of policies cancelled by the insurer in the quarter. X

1.14 State the number of all policies lapsed during the quarter. X

1.15

State the gross written premium for all policies lapsed during the quarter as per the breakdown below:

X

1.15.1 Direct marketing via telesales/call centre of the insurer; X

1.15.2 Direct marketing via telesales/call centre of affinity schemes; X

1.15.3 Direct marketing via telesales/call centres of any other third party; X

1.15.4 Direct marketing via internet; X

1.15.5 Marketing via aggregator and/or lead generator; X

1.15.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X

1.15.7 Face-to-face by insurer's juristic representatives; X

1.15.8

Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

1.15.9 Other (please specify). X

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

1.16 State the number of policies lapsed in the quarter as per the income group breakdown below:

X

1.16.1 Low income; X

1.16.2 Middle income; X

1.16.3 Upper income. X

1.17 State the number of cover types cancelled by the policyholder in the quarter.

X

2 DISTRIBUTION AND BINDER COSTS

2.1 Please state the total commission paid in the quarter as per the breakdown below:

X

2.1.1 Direct marketing via telesales/call centre of the insurer;

X

2.1.2 Direct marketing via telesales/call centre of affinity schemes;

X

2.1.3 Direct marketing via telesales/call centres of any other third party;

X

2.1.4 Direct marketing via internet; X

2.1.5 Marketing via aggregator and/or lead generator;

X

2.1.6 Face-to-face by insurer’s own individual representatives (“tied agents”);

X

2.1.7 Face-to-face by insurer's juristic representatives;

X

2.1.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);

X

2.1.9 Other (please specify). X

2.2 Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below:

X

2.2.1 Enter into, vary or renew a policy; X

2.2.2 Determining wording of a policy; X

2.2.3 Determining premiums under a policy; X

2.2.4 Determining the value of benefits under a

policy; X

2.2.5 Settling a claim under a policy. X

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

2.3 Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.

X

3 CLAIMS MANAGEMENT

3.1 State the number of claims that were reported to the insurer in the quarter.

X

3.2 State the value of claims that were reported in the quarter.

X

3.3 State the number of claims that were paid in the quarter.

X

3.4 State the value of claims that were paid in the quarter.

X

3.5 State the number of claims that were repudiated in the quarter.

X

3.6 State the value of claims that were repudiated in the quarter.

X

3.7 State the number of claims outstanding at the end of the quarter.

X

3.8 State the value of claims outstanding at the end of the quarter.

X

4 COMPLAINTS HANDLING

4.1 State the number of complaints received in the quarter as per the breakdown below:

4.1.1 Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits);

X

4.1.2 Complaints relating to product performance (including but not limited to investment performance);

X

4.1.3 Complaints relating to product accessibility, changes or switches (including termination charges);

X

4.1.4 Complaints relating to claims, in relation to: X

4.1.4.1 Claim handling process; X

4.1.4.2 Claims repudiated. X

5 ADD-ON/RIDER BENEFITS

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

5.1 Do you offer any of the following benefits as add-on/rider benefits to the policies? X

5.1.1 Emergency evacuation/transport; X

5.1.2 Legal Expenses; X

5.1.3 Riots and strikes; X

5.1.4 Cash back/No claim; X

5.1.5 Loyalty benefit as part of the product; X

5.1.6 Loyalty benefit as part of separate program; X

5.1.7 Other (please specify). X

5.2 State the number of policies with the add-on/rider benefits as per the breakdown below:

X

5.2.1 Emergency evacuation/transport; X

5.2.2 Legal Expenses; X

5.2.3 Riots and strikes; X

5.2.4 Cash back/No claim; X

5.2.5 Loyalty benefit as part of the product; X

5.2.6 Loyalty benefit as part of separate program; X

5.2.7 Other (please specify). X

CBR’s – Response to industry comments

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NON-LIFE INSURERS

LEVEL OF QUESTIONS

MAIN LEVEL

SUB LEVEL

1 3

GENERAL SHEET

1 PAYMENTS

1.1 Please state the total outsourcing fees paid to all other parties, including intermediaries and Underwriting Managers, in the last quarter.

X

1.2 Please state the total advertising and marketing expenses paid to all other parties in the last quarter as per the breakdown below:

X

1.2.1 Television X

1.2.2 Radio X

1.2.3 Print media X

1.2.4 Social media X

1.2.5 Other X

1.3

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:

1.3.1 Television X

1.3.2 Radio X

1.3.3 Print media X

1.3.4 Social media X

1.3.5 Other X

2 COMPLAINTS

2.1 State the number of all complaints received in the quarter.

X

2.2 State the number of complaints received in the quarter as per the breakdown below:

X

2.2.1

Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures);

X

2.2.2 Complaints relating to service; X

2.2.3 Complaints relating to advice in respect of each of the following distribution channels:

X

2.2.3.1 Insurer's "face-to-face" representatives;

X

2.2.3.2 Insurer's call centre representatives; X

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2.2.3.3 Independent FSP's X

2.2.3.4 Other

2.2.4 Complaints relating to complaints handling process;

X

2.2.5 Other complaints. X

2.3 State the number of all complaints finalised in favour of the policyholder in the quarter.

X

2.4 State the number of all complaints outstanding at the end of the quarter.

X