TCF from a UMA Perspective. Presented by Cornea Matthee Centriq Group Risk and Compliance Officer

Transcription

1 TCF from a UMA Perspective Presented by Cornea Matthee Centriq Group Risk and Compliance Officer

2 What to Expect? To understand the role and responsibilities of the Underwriting Management Agent from a TCF point of view.

3 Who is Centriq? 100% Santam Centriq Insurance Holdings Ltd Cell Captive Licences Centriq Insurance Company Ltd Centriq Life Insurance Company Ltd Nova Risk Partners Ltd Cell Captive a contractually ring-fenced structure created within the one legal entity. Mini-insurance licence In exchange for capital, cell owner issued preference shares which entitles cell owner to profits/losses of insurance business written into the cell captive. The cell pays Centriq a licence or management fee in exchange for use of licence and services provided. Centriq may participate in insurance profits/losses through reinsurance agreements with cells.

4 What Centriq does... Solutions Risk Finance First Party/Self Insurance Solutions housed in a Cell Captive, Contingency or Finite Risk policy Affinity Third Party Insurance Solutions provided to companies or groups where insurance business is ancillary to the primary business. Solutions generally housed in a Cell Captive structure. UMA Solutions Third Party Insurance Solutions provided to Underwriting Management Agencies that offer insurance to client base through the traditional intermediated market. Solutions housed in a Cell Captive or Promoter Account. Financial Highlights ,51bn 2,24bn 2,46bn GWP 58.1% 55.5% 54.9% Solvency Ratio AA- (2014) AA- A+ GCR Claims Paying ability

5 TCF Themes & Outcomes & Risk Appetite THEME OUTCOME EXPLANATION RISK APPETITE STATEMENT 1 Culture & Governance 2 3 Product Design and Marketing Customer Communication and Disclosure 4 Suitable Advice 5 Performance and Services against expectation 6 Claims, Complaints and Product Changes Customers are confident that they are dealing with firms where the fair treatment of customers is central to the firm culture. Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly. Customers are given clear information and are kept appropriately informed before, during and after the time of contracting. Where customers receive advice, the advice is suitable and takes account of their circumstances. Customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect. Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint. We must establish and maintain a corporate culture where the fair treatment of customers is a key consideration. The products and services marketed and sold (in the retail market) must be designed to meet the needs of identified customer groups and be targeted accordingly. Customers must be given clear information and be kept appropriately informed before, during and after the time of contracting. Where customers receive advice, it must be suitable and takes account of their circumstance. The products provided to customers must perform as they are intended to, and the associated service provided must be of an acceptable standard consistent with our promise to the customers. We will not impose unreasonable or unfair post-sale barriers to prevent customers from changing their product, switching provider, submitting a claim(s) or make a complaint(s).

6 TCF Outcomes & Risk Appetite THEME OUTCOME EXPLANATION RISK APPETITE STATEMENT 1 Culture & Governance 2 3 Product Design and Marketing Customer Communication and Disclosure 4 Suitable Advice 5 Performance and Services against expectation 6 Claims, Complaints and Product Changes Customers are confident that they are dealing with firms where the fair treatment of customers is central to the firm culture. Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly. Customers are given clear information and are kept appropriately informed before, during and after the time of contracting. Where customers receive advice, the advice is suitable and takes account of their circumstances. Customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect. Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint. We must establish and maintain a corporate culture where the fair treatment of customers is a key consideration. The products and services marketed and sold (in the retail market) must be designed to meet the needs of identified customer groups and be targeted accordingly. Customers must be given clear information and be kept appropriately informed before, during and after the time of contracting. Where customers receive advice, it must be suitable and takes account of their circumstance. The products provided to customers must perform as they are intended to, and the associated service provided must be of an acceptable standard consistent with our promise to the customers. We will not impose unreasonable or unfair post-sale barriers to prevent customers from changing their product, switching provider, submitting a claim(s) or make a complaint(s).

7 TCF MI Framework (Proposed steps) TCF POLICY (TCF Broker Declaration) TCF MANAGEMENT INFORMATION (MI) POLICY (Risk Appetite Statements) 1. TCF Objectives & Risk Appetite Statements Translate the corporate strategy into targeted TCF outcomes and explicit statements of TCF risk 2. Business Measures Quantitative and qualitative metrics that can be used to articulate the objectives and risk appetite statements 4. Monitoring & reporting 5. Management & decision making 3. Tolerance / Limit Framework Determine the limits or thresholds against the measures 6. Governance State the roles & responsibilities of individuals charged with delivering TCF outcomes and risk appetite

8 TCF Governance & Reporting (Proposed Structure) Board TCF Declaration, Risk Appetite and MI Dashboard 1 st Line TCF Ownership Management Meetings Managing and Decision Making Embedding of TCF into business in line with TCF Policy & Risk Appetite: Translate risk appetite and make business specific Apply TCF outcomes and appetite to relevant business activities Identify measures / metrics to test extend of delivering TCF Monitor, manage and report performance against TCF outcomes and risk appetite Remediation / Improvement 2 nd Line Integration, Oversight, Risk Control & Monitoring Compliance & Risk Management Alignment, check, Oversight Direction, overall policy and standard setting. Key activities include: Designs and deploy the overall TCF and TCF and MI policy Develop and monitor policies and procedures Monitors adherence to policy, standards, strategy and risk appetite statements 3 rd Line Independent Assurance & Validation External Compliance External Audit Independent Check Independent & objective assurance over the effectiveness of TCF standards & business compliance Assurance that the risk management process is functioning as designed & identifies improvement opportunities TCF MI and Risk Governance Structure Risk Management System

9 How adversely are customers affected (Likelihood that customers will be affected)? Risk Quantification (Rating) Low Medium High Very Likely Likely Unlikely % Minor 10,1-50% Moderate 50,1-100% Major Impact / Seriousness (How many customers are affected per product?)

10 What does the UMA Binder Holder do? Sign-off (tariffs, wordings) Approve Meetings Audits Develop Product Underwrite Train Brokers Market Product Collect Premium Admin Product Sell Product Advice Market Product Collect Premium Meetings Act obo Client 1. Queries 2. Claims 3. Complaints 4. Compliments 5. Feedback 6. Cancellations DATA 7. Claims/loss ratio 8. Lapse ratio 9. Sales Average 10. Complaints 11. Cancellations Insurer UMA Binder Holder TCF BAU Root Cause Analysis Investigations Meetings Performance Review & Remuneration Remedial Action: Train, Retrain, Performance Manage, Disciplinary Action, Audit, Terminate, Enhance, Change, Discontinue Reporting and Escalation Monitoring Broker Customer REQUIRES 15. Broker Product Training 16. Staff Training (Claims, Complaints, Rejections, Cancellations, Customer Care) 17. Segmentation (Understand & know customer) 18. Sophistication determines simple & plain language 19. Weekly & Monthly (meetings, Reporting) 20. Sales Process, Premium Collection UMA BINDER FUNCTIONS 12. Determine wording 13. Determine pricing 14. Determine benefits 15. Enter into, vary, renew (cancel and refuse to renew a policy & declare a policy void) 16. Settle & Reject Claims

11 OUTCOMES Linking TCF to Operations / Functional Areas Product Life Cycle Product & Service Design Promotion & Marketing Advice Point of Sale Information after point of sale Complaints and claims handling 2 2, 3 2, 3, 4 3, 5 3, 5 5, 6 CULTURE & GOVERNANCE (outcome 1)

12 MI dashboard Primary Department & Evidence Distribution Value Chain Product & Service Design Promotion & Marketing Advice Point of Sale Information after point of sale Complaints and claims handling Marketing, Sales, Claims, Complaints Brochure, SMS, Website, Flyer, Letters Sales, Retentions, Customer Care, Training Sales, Scripts, Quality Assurance Welcome Letter, Policy, Disclosure, Schedule, SMS Website, Ongoing Communication CULTURE & GOVERNANCE HUMAN CAPITAL, COMMUNICATION, 3 RD PARTIES

13 TCF Responsibilities UMA view Outcome 2, 3 Underwriting TCF Product Governance Policy TCF Product Register TCF Sign-Off Sheet Remedial Action Register Outcome 4, 5, 6 Claims / Complaints Claims Policy Complaints Policy Incident Register Root Cause Analyses & Feedback Remedial Action Register SOPs Compliance Policy TCF Policy MI Policy Supporting Policies Meeting Minutes Training Reporting TCF Committee Outcome 1 Outcome 1 Compliance Audit Report TCF Remedial Action Checklist in place Tracking Remedial Action Register Ongoing Monitoring TCF Broker Declaration Business (Partner/Broker Management) TCF MI Dashboard Broker Meetings Insurer Meetings Take-On (Due diligence) of broker TCF Remedial Action Register Legal Breach Letter

14 CONTROLS / DOCUMENTS TCF Evidencing Company Directors TCF Policy MI Policy & Dashboard Claims & Complaints specific Claims Policy Complaints-Handling Policy Incident Register Claims & Complaints Remedial Action Register Reporting Underwriting specific Underwriting Policy (incl. PPR Checklist) Underwriting TCF Product Governance Policy Product Register & Risk Rating (target market description / write up) Sign-off Sheet Underwriting Remedial Action Register Reporting Business specific SOPs (incl. DD) TCF Broker Declaration TCF Business Monitoring Tool Meeting Agenda and Minutes Reports Exco / management meeting report Compliance monitoring and audit reports TCF status report

15 TCF MI (outcome 1 & 2) TCF Outcomes Outcome 1: Culture & Governance Outcome 2: Product Design & Marketing MI Required TCF framework, policy, charter, constitution, declaration, policies and procedures aligned TCF included in measuring performance (KRA, KPI, KPA) Staff awareness training / refresher training (staff / brokers) No. of staff receiving Coaching / Retraining following complaints / TCF breach No. of remedial / mitigating actions implemented / taken No. of staff receiving Coaching / Retraining following complaints / TCF breach TCF Forum / Committee / Champion / Representative Meeting Minutes / Board and Sub-Committee Minutes (Manco, Exco, Team meetings) Market Segmentation done and operates in intended market segment profile Research done - Number of focus groups held before product is launched and summary of research results All generated marketing and customer communication is designed for its intended target market and is easy to understand Products advertised and promoted in line with TCF Plain language implementation - % of customer communication adjusted for plain language Number of compliance breaches picked up by the in-house approval process Volume of complaints by promotion type (advertisement, Direct Marketing (telephone, Internet, media insert, direct mail or electronic mail), brokers,etc.) Complaints feedback - Complaints stats relating to product/product features/bundles/charges/ premiums/add-ons and loyalty benefits

16 TCF MI (outcome 3, 4 & 5) TCF Outcomes Outcome 3: Communication & Disclosure Outcome 4: Suitable Advice Outcome 5: Performance & Services against Expectations (recording and analysing data / stats) MI Required Provides the customer with all the information needed to make an informed purchasing decision (e.g. Disclosure document, Restrictions and exclusions, etc) Number of policies issued, by type of sales channel (via call centre, internet, agreggators, lead generators, face to face, etc) Gross premium written for all new policies and not taken up by type of sales channel (via call centre, internet, agreggators, lead generators, face to face, etc) Up to date client contact details - Number of clients with address unknown as % of client base and undelivered communication expressed as % of total communication sent Complaints relating to broker information supplied / relating to quality of information provided to customers, including advertising, service letters and other disclosures/communication Percentage of clients contacted following completion of satisfaction survey Percentage of sales staff completing new product training within a given period Application form completed by customer in line with TCF Recordkeeping of Advice that is provided Advice monitoring - % of cases monitored for advice, % of clients from monitored sample that received inappropriate advice and mitigating action taken Ensures that the customer has reasonable access to the Binder Holder and Intermediary post sale. Service Provider/Supplier stats in respect of perfomance and service level feedback from customers Communications - sms, social media, advertisements, letter Clients contacted to notify unsuitability of product following TCF review Number of reported claims Number of rejections Number of outstanding claims

17 TCF MI (outcome 6) TCF Outcomes Outcome 6: Claims, Complaints & Product Change MI Required Correctly report on and analyse claims statistics Exposure to bundles - Claims experience of embedded risk products for all products sold Training on Complaints-Handling Number of Complaints : Received per Type of product Numberof Claims Complaints : Received Numberof Claims Complaints : Resolved Number of Claims Complaints : Pending Numberof Claims Complaints : Rejected Complaints monitored and action taken (root cause analysis) Number of complaints relating to the same root cause per specific partner Remedial Action taken Volume and percentage of complaints referred to FOS Records evidence of complaint handling process and resolution Follow FSB FAIS turnaround time Notifies Centriq of key themes arising that indicate the need for possible changes to products or service solutions Complaint stats reviewed by senior management

18 MI Checklist What to monitor and report on (FSA) THEME OUTCOMES MI WHAT DOES THE MI SHOW Culture and Values Advertising and Financial Promotion 1 2,3,5 % of staff who completed general TCF training (sales and non-sales) % of staff who completed additional TCF training specific to their area # of reps / agents / staff who received additional training following high volumes of complaints # of TCF goals in place by business area / division % of TCF goals achieved # of sales / non-sales rewarded for meeting TCF targets # of staff rewarded for suggestions to improve service Volume of complaints by promotion type # of compliance breaches picked up by internal approval process # of compliance breaches by picked up by Regulator # of promotions pre-tested with target customers Indicative of TCF awareness, strategy communication and culture Unclear or inaccurate promotions May indicate: - approval processes are operating satisfactorily - a poor technical understanding in the marketing areas - a poor understanding of what constitutes using clear, fair and not misleading information Misleading info to customers REMEDIAL ACTION Training needed Pre-testing required

19 MI Checklist What to monitor and report on (FSA) THEME OUTCOMES MI WHAT DOES THE MI SHOW REMEDIAL ACTION Point of Score quality of advice / info provided after Unsuitable sales sale and mystery shopping Product overly complex 2,3,4 Precompletion Telephone monitoring Product info unclear Volume of pre-completion customer queries After sales service 1,2,3,4,6 % of customers contacted within x yrs./months of sale and reason for contact # of customers contacted to inform of better deal # of customers contacted within 3 months to inform of other products # of customers contacted to notify of product unsuitability following TCF review # of customers contacted after completion of satisfaction survey Overall service satisfaction score for a period out of 10 Measure of standard of customer care Measure of standard of customer care post sale Serious compliance breaches due to mis-selling Fairness related questions: - What does this product do - Why did you buy it Indicates whether customer understood product, and the service he may expect to receive

20 MI Checklist What to monitor and report on (FSA) THEME OUTCOMES MI WHAT DOES THE MI SHOW REMEDIAL ACTION Sales 2,3,4,5 Complaints 1-6 Sales volumes by product type Sales volumes by commission Sales volumes by rep / agent Sales expectations Offer to completions rate Offer to completions time Cancellation within cooling off period Early redemption rate QA percentage # of new products introduced and sales staff completing new product training Volume of complaints Complaints by rep / agent Complaints by product Complaints upheld internally Complaints not upheld internally Volume and % of complaints referred to Ombud % of complaints upheld by Ombud % of complaints not upheld by Ombud Complaints resolution time (1, 4, 6 weeks) Ombud recommendations Product Suitability Product affordability Mis-selling Misleading information Product too complex Wrong targeting Unsuitable sales Not fully understanding the key terms Lack of suitability of advice Poor product knowledge Inappropriate recommendation Inadequate training Mis-selling Training need Unclear, misleading or unsuitable marketing material Lack of clarity of key terms Misunderstanding Unfair complaints handling process Performance measurements Action taken to improve standards Review scripts to ensure proper assessment of suitability and affordability Re-train Review training programme and material Increased and focused quality assurance (QA) Performance reviews and corrective actions warning, dismissal, commission penalty Monitor and Report Review product wording Re-train Review scripts Review complaints handling process

21 MI Checklist What to monitor and report on (FSA) THEME OUTCOMES MI WHAT DOES THE MI SHOW Feedback from Staff Feedback from Customers 1-6 3,5,6 Periodic feedback sessions / workshops to ask their opinion o whether the product / service sold pose any risk to the fair treatment to customers TCF staff suggestion / ideas scheme related to incentives Meeting minutes / Session minutes Reporting on ideas to senior management Asking open-ended questions: - What does this product do - Why did you buy it - Did you buy this product based on the agent info only - How where you charged for this product Evidence embedding TCF within culture Helping business identify where action can be taken to implement TCF Customer understanding of the product or service REMEDIAL ACTION Review product wording Review script Re-train

22 Remedial Action / Risk Response / Risk Mitigation Remedial Action/Risk Response/Risk Mitigation To decide, in relation to the risk, one of the following: Tolerate risk accepted (guided by risk appetite statements in relation to risks) Treat agree on action, due date, and person to mitigate risk Terminate specific product or line of business / breach or cancellation letter NOTE: Risk Appetite Statement: If the risk is agreed or objectively viewed as material / significant, and management decides to tolerate the risk, Risk Officer is responsible to escalate the matter to the RFC, Board etc. Examples: risk exceeds statement in risk appetite document

23 MI Brokers What to do with the data you have: Analyse broker performance: - Disclosures regarding product features - List of material disclosures and significant conditions - Simplified and standardised disclosure documentation - Verifying information up front to determine the customer s risk profile - Claims - Complaints - Rejections - Commission - Ongoing communication - Meetings - Training attendance NB Avoid underwriting at claims stage!!!

24 MI Product, Service Providers What to do with the data you have: Monitor product performance - What is the customer s expectation - Appropriate and affordable - Against target market description - Competitiveness on price or product (benefits) - Simplified and plain language - Adequate distribution channel - Key Information Document (KID) - Website usage: products, key features, material disclosures and significant conditions, claims process, complaints process - Premium adjustment (upward and downward) Analyse service provider service levels - Complaints - Expectation management - Consumer Protection - Ethical behaviour

25 MI Claims, Complaints, Rejections What to do with the data you have: Analyse Claims - Per product type - Claims ratio - Claims vs Sales (per product / per broker) Analyse Complaints (Root-Cause) - Link to Outcome - Determine Remedial Action - Monitor overturn rate - Response and resolution timeline - Complaints vs Claims (per product / per broker) - General, FAIS, OSTI Analyse Rejections in relation to brokers (disclosure before sales) - Why would the customer think he could claim - Did the customer understand the terms and conditions - Has the customer been made aware of the limitations / his obligations - Continued service by broker after point of sale

26 TCF Process UMA Specific Point of Departure: Each business unit / function to fully understand and implements the undertakings stated in the TCF Declaration. This requires you to: Appoint a TCF Champion Train staff Complete and continuously monitor the TCF Dashboard Engage actively with Brokers / Insurers for guidance and assistance (training, tools, implementation) Include TCF in the Meeting Agenda & Minutes with brokers / insurer Engage continuously with the other business units to obtain TCF MI Evidence through Management Information (MI) that TCF is embedded, monitored and reported on (especially in relation to remedial action)

27 TCF Process UMA Specific When a TCF Remedial Action is determined / proposed, then: Provide information / documentation to support remedial action Request and set up a Meeting with the Broker / Partner / BU to discuss proposed remedial action (Meeting Agenda and Minutes) Include Underwriting/Claims/Compliance/TCF Champion in meeting Agree with Broker / Partner / BU on proposed remedial action: detailed actions, timelines and responsible persons(s) Report and record agreed actions, timelines, responsible person for evidencing purposes Ensure changes implemented by the broker / partner / BU NB monitor progress!!!

28 And finally What TCF is NOT

29 Outcome 1: Culture?

30 Outcome 1: Culture?

31 Outcome 2: Customer Comm & Disclosure?

32 Outcome 2: Customer Comm & Disclosure?

33 Outcome 3: Product Design & Marketing?

34 Outcome 3: Product Design & Marketing?

35 Outcome 5: Performance & Services against expectation?

36 Outcome 6: Complaints Handling?

37 Outcome 6: Post-sale Barriers?

38 Outcome 6: Post-sale Barriers?

39