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Misrepresentation, Non-Disclosure and Breach ... - Law Commission

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Section 6 Case Study - Critical Illness Cover<br />

The aggregate impact on consumers is estimated to be £0.470 million per<br />

annum; however, the impact of these proposals affects consumers quite<br />

differently depending on their characteristics.<br />

It is not possible to exactly predict the impact of these proposed reforms on<br />

all consumers. Honest consumers are likely to be better off as a result of<br />

having claims paid (which may not have been previously the case), as well as<br />

benefiting from regulation per se. Consumers that deliberately <strong>and</strong> recklessly<br />

misrepresent <strong>and</strong> are detected doing so will be worse off as a result of these<br />

proposals due to the fact that insurance companies will have the right to<br />

retain these premiums confirmed.<br />

We estimate that the wider benefits accruing to both consumers <strong>and</strong> firms<br />

associated with a reduction in dispute resolution are estimated to be £0.391<br />

million per annum.<br />

The aggregate recurring economic benefits of these proposals on the critical<br />

illness market are estimated to be in the region of £0.862 million to £1.120<br />

million per annum depending on the costs associated with recurrent<br />

administration costs. This is presented in the Table below.<br />

This aggregate estimate is driven by the large impacts on consumers <strong>and</strong> in<br />

particular, the large positive impact on consumers that are honest in the<br />

claims they bring to some insurance companies <strong>and</strong> the large negative impact<br />

on those consumers that deliberately or recklessly misrepresent.<br />

Excluding the impact on consumers, the aggregate impact on firms through<br />

the increase in the claims paid, fraudulent premiums retained, increased<br />

premiums charged; recurrent administration fees <strong>and</strong> avoidance of disputes<br />

(which benefit firms <strong>and</strong> consumers) is relatively cost neutral on an ongoing<br />

basis.<br />

London Economics<br />

June 2007 55

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