Life & Health Insurance Breakout Session

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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