Life & Health Insurance Breakout Session

Erica Hiemstra, Canadian Life & Health Insurance Association, captures challenges identified by the group.

Erica Hiemstra, Canadian Life & Health Insurance Association, captures challenges identified by the group.

The group opting for the life and health breakout first identified, and then fully vetted five topics, working to distill best-of-the-best best practices.

Self-reporting for corporations

  • Corporations finding issues in one state should check and correct in all states
  • Reports should include active issue solutions
  • Self-reporting across regulatory entities is recommended because regulators are sharing information—best to look proactive.
    • Advising domestic regulators especially recommended, particularly if fines have been assessed in another state
    • Report to other sectors if company doesn’t agree with a regulator’s findings? Probably, but be sure to include qualifying information on source of disagreement.

Agent suitability: When an agent issue is sent by the regulator

  • If a consumer has been harmed, try to make them whole
  • Recommended actions to take regarding the agent:
    • Talk to the agent and make expectations clear
    • Get agent’s statement
    • Monitor the agent’s activities
    • Conduct a book of business review and consult with the MGA
    • Audit communications with affected clients
    • Suspend the agent
    • Consider ending relationship with agent (Remember, termination for cause carries reporting requirements.)
  • If the agent doesn’t respond, request regulator assistance

Complaint jurisdiction conflicts: Which state own the complaint?

  • Does the complaint fall in the jurisdiction where policy was issued or the jurisdiction where the consumer resides? Approaches vary:
    • Some states will only deal with complaints involving their residents
    • Some states have extra-territorial authority
    • Some states will refer issues to other states via the consumer, insurer or anther regulator
  • The result can be a consumer left in regulatory limbo
  • Insurers may need to decide which state law to apply and which regulators to keep informed

How to finalize, or close, a repeat complaint

  • Make clear to consumer that no new issue or information has been presented, so the insurer has no more responses to give
  • Send a final communication under a more senior signature
  • Make a joint call to the consumer with your regulator
  • Give customer the option to call the regulator
  • Send a cease and desist letter
  • Stop responding and just add communications to file

Are negative comments from a customer feedback exercise considered to be complaints? (Examples: negative comments collected during a post-sale written or telephone survey, or from a net producer score survey)

  • Negative feedback is often a repeat complaint, so scan for negative feedback and check the results against existing complaints. Then circle back to the consumer, as necessary.
  • Post-sale surveys can have a positive effect by:
    • Cutting down the number of complaints (because the customer understands the product from the start)
    • Providing a record that the consumer understands the product, which could disprove a statement made in a future complaint

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