
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