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Modern Insurance Magazine Issue 62

This issue features... Insight: A Guide to the New Consumer Duty, with Branko Bjelobaba, FCII Interview: Doing the Right Thing, with Matt Brewis, Financial Conduct Authority (FCA) Interview: A New Consumer Freedom, with Sam Richardson, Which? Money Editorial Board: Find out what our editorial board panel of experts have to say in this edition of Modern Insurance Magazine Associations Assemble: Modern Insurance's panel of resident associations outline the burning issues in insurance Just a Thought with Eddie Longworth... Suppliers Must Also Deliver Consumer Duty Obligations Consumer Intelligence: Avoiding Consumer Harm in the Consumer Duty Age Modern Claims Awards 2024: Meet the Judges EDAM Group: Meet the Company, 'Internal Satisfaction Informs Customer Satisfaction at EDAM Group' Dive In Festival: Dive In's 'Below the Surface' Event Shines a Light on Insurance Industry's Diversity and Inclusion Challenges Thinking Upside Down: Consumer Duty: An Illusion?? with Michael Lewis, CEO, Claim Technology I Love Claims / ARC 360: The Unintended Consequences of Consumer Duty Europcar: Can the Insurance Sector Help to Accelerate the Adoption of EV? with James Roberts, Head of Insurance Sales 10 Mins with… Ajay Mistry, Founder and Director, Gambit Partners, & Co-Founder and Co-Chair, iCAN (The Insurance Cultural Awareness Network) Insur.Tech.Talk - Interviews with Farooq Sheikh, Global Head of Insurance at Unqork; Brent Williams, Founder and CEO at Benekiva; Juan Mazzini, Head of Insurance Practice APAC, EMEA, LATAM at Celent; Meredith Barnes-Cook, Partner at ReSource Pro Consulting; and Ron Rock, Managing Director - Financial Services at JobsOhio Insur.Tech.Talk Editorial Board - Experts from within the insurtech sector and beyond join us once more to share their unique insights!

This issue features...

Insight: A Guide to the New Consumer Duty, with Branko Bjelobaba, FCII
Interview: Doing the Right Thing, with Matt Brewis, Financial Conduct Authority (FCA)
Interview: A New Consumer Freedom, with Sam Richardson, Which? Money
Editorial Board: Find out what our editorial board panel of experts have to say in this edition of Modern Insurance Magazine
Associations Assemble: Modern Insurance's panel of resident associations outline the burning issues in insurance
Just a Thought with Eddie Longworth... Suppliers Must Also Deliver Consumer Duty Obligations
Consumer Intelligence: Avoiding Consumer Harm in the Consumer Duty Age
Modern Claims Awards 2024: Meet the Judges
EDAM Group: Meet the Company, 'Internal Satisfaction Informs Customer Satisfaction at EDAM Group'
Dive In Festival: Dive In's 'Below the Surface' Event Shines a Light on Insurance Industry's Diversity and Inclusion Challenges
Thinking Upside Down: Consumer Duty: An Illusion?? with Michael Lewis, CEO, Claim Technology
I Love Claims / ARC 360: The Unintended Consequences of Consumer Duty
Europcar: Can the Insurance Sector Help to Accelerate the Adoption of EV? with James Roberts, Head of Insurance Sales
10 Mins with… Ajay Mistry, Founder and Director, Gambit Partners, & Co-Founder and Co-Chair, iCAN (The Insurance Cultural Awareness Network)
Insur.Tech.Talk - Interviews with Farooq Sheikh, Global Head of Insurance at Unqork; Brent Williams, Founder and CEO at Benekiva; Juan Mazzini, Head of Insurance Practice APAC, EMEA, LATAM at Celent; Meredith Barnes-Cook, Partner at ReSource Pro Consulting; and Ron Rock, Managing Director - Financial Services at JobsOhio
Insur.Tech.Talk Editorial Board - Experts from within the insurtech sector and beyond join us once more to share their unique insights!

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ISSUE<br />

<strong>62</strong><br />

ISSN 2515-3803<br />

CONSUMER DUTY:<br />

CLEARER STANDARDS<br />

Doing the<br />

Right Thing<br />

with Matt Brewis, FCA<br />

A New Consumer<br />

Freedom<br />

with Sam Richardson,<br />

Which? Money<br />

A Guide to the New<br />

Consumer Duty<br />

with Branko Bjelobaba, FCII<br />

Europcar:<br />

Can the insurance sector<br />

help to accelerate<br />

the adoption of EV?<br />

INSUR.TECH.<br />

TALK<br />

Insurtech Insights<br />

2023 Contributors Media Partners


Put your trust<br />

in our company<br />

and our people.<br />

Credit Hire and Credit Repair<br />

solutions from a company that cares.<br />

edamgroup.co.uk<br />

hello@edamgroup.co.uk | 0330 333 3344


WELCOME<br />

Hello readers,<br />

Welcome to <strong>Issue</strong> <strong>62</strong> of <strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong>, where we’re<br />

talking all about the new Consumer Duty in <strong>Insurance</strong>.<br />

Back in July, the Financial Conduct Authority (FCA) introduced a new set of rules<br />

and guidelines for financial services, one that hopes to set higher and clearer<br />

standards for consumer protection. With a focus on positive outcomes, insurer<br />

firms must now take additional measures to minimise scope for foreseeable harm,<br />

embracing reasonable steps to act in ‘good faith’, as well as evidencing how they<br />

are supporting customers with their bespoke financial objectives.<br />

Amelia Barlow, Editor<br />

For a detailed overview of these regulations, head to p.8 to read a useful guide<br />

on the new Consumer Duty from Branko Bjelobaba, FCII. On p.12, we’ve also sat<br />

down with Matt Brewis, Director of <strong>Insurance</strong> at the Financial Conduct Authority, in<br />

order to capture the regulator’s perspective - as well as offering a platform for the<br />

consumer voice from Sam Richardson, Deputy Editor at Which? Money, on p.14.<br />

There’s also a diverse selection of thought leadership contributions from our inhouse<br />

editorial board of experts, starting with Carpenters Group on p.17. You’ll<br />

also find several articles from our pool of esteemed industry associations from p.29.<br />

<strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong> wouldn’t be whole without our valued INSUR.TECH.<br />

TALK section (in partnership with Insurtech Insights), bringing you the very latest<br />

updates from the world of insurtech through a series of highly relevant interviews<br />

around the definition of ‘Consumer Duty in <strong>Insurance</strong>’.<br />

As we collectively find our feet in the new Consumer Duty landscape, I hope this<br />

issue goes some way to further clarify the intricacies of the new guidance for you,<br />

our valued readership.<br />

Until next time,<br />

Rachael Pearson, Project Manager<br />

Amelia Day Barlow,<br />

Editor,<br />

<strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong>.<br />

amelia@charltongrant.co.uk<br />

ISSUE <strong>62</strong><br />

ISSN 2515-3803<br />

Editor<br />

Amelia Barlow<br />

Project Manager & Events Sales<br />

Rachael Pearson<br />

<strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong><br />

is published by Charlton Grant Ltd ©2023<br />

All material is copyrighted both written and illustrated. Reproduction in part or whole is strictly<br />

forbidden without the written permission of the publisher. All images and information is collated<br />

from extensive research and along with advertisements is published in good faith. Although the<br />

author and publisher have made every effort to ensure that the information in this publication<br />

was correct at press time, the author and publisher do not assume and hereby disclaim any<br />

liability to any party for any loss, damage, or disruption caused by errors or omissions, whether<br />

such errors or omissions result from negligence, accident, or any other cause.<br />

MODERN INSURANCE | 3


14<br />

Contents<br />

12<br />

49<br />

51<br />

55<br />

4 | MODERN INSURANCE


8<br />

12<br />

14<br />

17<br />

29<br />

39<br />

41<br />

42<br />

45<br />

46<br />

47<br />

Insight<br />

A Guide to the New Consumer Duty,<br />

by Branko Bjelobaba, FCII<br />

Interview<br />

Doing the Right Thing, with Matt<br />

Brewis, Director of <strong>Insurance</strong> at the<br />

Financial Conduct Authority (FCA)<br />

A New Consumer Freedom, with<br />

Sam Richardson, Deputy Editor at<br />

Which? Money<br />

Editorial Board<br />

Find out what our editorial board<br />

panel of industry experts have to say<br />

in this edition of <strong>Modern</strong> <strong>Insurance</strong><br />

<strong>Magazine</strong>.<br />

Associations<br />

Assemble<br />

<strong>Modern</strong> <strong>Insurance</strong>’s panel of resident<br />

associations outline the burning<br />

issues in insurance<br />

Features<br />

Just a Thought with Eddie<br />

Longworth…<br />

Suppliers Must Also Deliver<br />

Consumer Duty Obligations<br />

Consumer Intelligence: Avoiding<br />

Consumer Harm in the Consumer<br />

Duty Age<br />

<strong>Modern</strong> Claims Awards 2024: Meet<br />

the Judges<br />

Meet the Company: Internal<br />

Satisfaction Informs Customer<br />

Satisfaction at EDAM Group<br />

Dive In Festival: Dive In’s ‘Below the<br />

Surface’ Event Shines a Light on<br />

<strong>Insurance</strong> Industry’s Diversity and<br />

Inclusion Challenges<br />

Thinking Upside Down:<br />

Consumer Duty: An Illusion??<br />

by Michael Lewis, CEO, Claim<br />

Technology<br />

49<br />

51<br />

53<br />

I Love Claims / ARC 360<br />

The Unintended Consequences of<br />

Consumer Duty<br />

Can the insurance sector help to<br />

accelerate the adoption of EV? with<br />

James Roberts, Head of <strong>Insurance</strong><br />

Sales, Europcar Mobility Group UK<br />

10 Mins with...<br />

10 minutes with... Ajay Mistry,<br />

Founder and Director, Gambit<br />

Partners, & Co-Founder and Co-<br />

Chair, iCAN (The <strong>Insurance</strong> Cultural<br />

Awareness Network)<br />

Insur.Tech.Talk<br />

Interviews<br />

56 Welcome<br />

Megan Kuczynski, President,<br />

Insurtech Insights<br />

57 Unqork<br />

Farooq Sheikh, Global Head of<br />

<strong>Insurance</strong>, Unqork<br />

58 Benekiva<br />

Brent Williams, Founder and CEO,<br />

Benekiva<br />

60 Celent<br />

Juan Mazzini, Head of <strong>Insurance</strong><br />

Practice APAC, EMEA, LATAM, Celent<br />

<strong>62</strong><br />

ReSource Pro Consulting<br />

Meredith Barnes-Cook, Partner,<br />

ReSource Pro Consulting<br />

64 JobsOhio<br />

Ron Rock, Managing Director -<br />

Financial Services, JobsOhio<br />

65<br />

Insur.Tech.Talk<br />

Editorial Board<br />

Experts from the insurtech sector<br />

join us once more to share their<br />

unique insights!<br />

INSUR.TECH.TALK BOARD<br />

Disclaimer: Our publications contain advertising material submitted by third parties. Each individual advertiser is solely responsible for the content of its advertising<br />

material. We accept no responsibility for the content of advertising material, including, without limitation, any error, omission or inaccuracy therein. We do not endorse,<br />

and are not responsible or liable for, any advertising or products in such advertising, nor for any any damage, loss or offence caused or alleged to be caused by, or in<br />

connection with, the use of or reliance on any such advertising or products in such advertising.<br />

MODERN INSURANCE | 5


Editorial Board<br />

17<br />

19<br />

21<br />

PREPARING STAFF FOR<br />

THE NEW CONSUMER<br />

DUTY<br />

Paul Challinor, Commercial Director,<br />

Carpenters Group<br />

THE NEW CONSUMER<br />

DUTY: A CHANGE IN<br />

DISTRIBUTION<br />

Will Prest, Product Manager,<br />

ParaCode<br />

SUPPORTING INSURERS<br />

WITH THEIR CONSUMER<br />

DUTY OBLIGATIONS<br />

Jim Loughran, CEO, e2e Total Loss<br />

Vehicle Management<br />

MITIGATING THE EFFECTS<br />

OF RISING CLAIMS COSTS<br />

Tom Lawrie-Fussey, senior director<br />

of product management, U.K and<br />

Ireland, LexisNexis Risk Solutions<br />

EMBRACING THE NEW<br />

CONSUMER DUTY<br />

Simon Hunt, Commercial & Services<br />

Director, National Windscreens<br />

23<br />

25<br />

BASF UK X STEM:<br />

CURIOSITY AND<br />

CREATIVITY<br />

Dr. Natalie Wong, Marketing &<br />

Portfolio Management Lead, BASF<br />

Automotive Refinish UK & Ireland<br />

HAS THE ‘AS-A-SERVICE’<br />

TREND ARRIVED IN THE<br />

CLAIMS INDUSTRY?<br />

Lorna Turner, Director of Business<br />

Development, Activate Group<br />

PROVIDING FAIR,<br />

FLEXIBLE AND INCLUSIVE<br />

SERVICES<br />

Hannah Gardner, Customer<br />

Enhancement Service Lead,<br />

Crawford & Co.<br />

CONSUMER DUTY<br />

REGULATIONS AND<br />

THE WORLD OF VEHICLE<br />

RECOVERY<br />

Mick Jennings, Managing Director,<br />

Nationwide Vehicle Assistance<br />

(NWVA)<br />

Editorial Board Contributors<br />

6 | MODERN INSURANCE


EUROPCAR<br />

NEW BRAND BLOCK<br />

Color gradient background<br />

File: 20151645E<br />

Date: 7/10/2015<br />

AC/DC validation :<br />

Client validation :<br />

Insur.tech. talk and<br />

Editorial Board<br />

27<br />

THE NEW CONSUMER<br />

DUTY AT RGI<br />

SOLUTIONS<br />

Sarah Glenn, Commercial<br />

Director, RGI Solutions<br />

OFFERING CUSTOMER<br />

CHOICE AND<br />

PROVIDING A DIGITAL<br />

FOOTPRINT<br />

Andrew Chander,<br />

Sales Director, FMG<br />

66<br />

67<br />

68<br />

69<br />

70<br />

31<br />

71<br />

72<br />

73<br />

75<br />

Welcome - Bradley Collins, Chief<br />

Commercial Officer, Insurtech<br />

Insights<br />

AXA Retail - Tara Foley, CEO of AXA<br />

Retail<br />

Munich Re - Dr. Fabian Winter, Group<br />

Chief Data Officer at Munich Re<br />

EIS - Anthony Grosso, CMO of EIS<br />

BIBA<br />

Zego Using - Sten the Saar, Consumer CEO of Duty Zego to Deliver<br />

Good Outcomes<br />

David Sparkes, Regulation Director,<br />

Aon British - Marguerite <strong>Insurance</strong> Soeteman-Reijnen,<br />

Brokers’ Association<br />

Chairman (BIBA) Executive Board, Aon<br />

Holdings<br />

MGAA<br />

Arma MGAs: Karma Vital - Support Ben Smyth, for Brokers CEO,<br />

Arma Mike Karma Keating, CEO, Managing General<br />

Agents’ Association (MGAA)<br />

Revolut - Balázs Gáti, Global Head of<br />

<strong>Insurance</strong>, Revolut<br />

The Justice Gap<br />

BIMA<br />

Mike<br />

- Mathilda<br />

Benner, Chief<br />

Strom,<br />

Executive,<br />

Co-Founder<br />

& Deputy<br />

Association<br />

CEO,<br />

of<br />

BIMA<br />

Personal Injury Lawyers<br />

(APIL)<br />

WTW - Pardeep Bassi, Global<br />

Proposition CHO Leader – Data Science,<br />

WTW<br />

Consumer Duty: Overly Onerous, or<br />

a Necessary Check on Overzealous<br />

Capitalism?<br />

Insur.Tech.Talk<br />

Anthony Hughes, Chair and CEO, Credit<br />

Hire Organisation (CHO)<br />

33 APIL<br />

Editorial Board<br />

35 MASS<br />

Experts<br />

2024:<br />

from<br />

A Year<br />

within<br />

for Statutory<br />

the Insurtech<br />

Review<br />

sector Sue Brown, and beyond Chair, share Motor their Accident unique<br />

insights. Solicitors In this Society issue, (MASS) we look at<br />

balancing automation with customer<br />

satisfaction, FOIL the concept of ‘digital<br />

transformation’, Consumer Duty and & how Claims new signals<br />

point Jonathan to technology Drake, Member as a solution of the to Forum<br />

address of <strong>Insurance</strong> economic Lawyers concerns. (FOIL) and<br />

Partner at DWF<br />

37 NBRA<br />

Consumer Protection in the Automotive<br />

Repair Industry<br />

Thomas Hudd, National Technical<br />

Manager, Nationwide Bodyshop Repair<br />

Association (NBRA)<br />

INSUR.TECH.TALK BOARD<br />

CII<br />

Is the insurance sector ready for the<br />

Consumer Duty?<br />

Dr Matthew Connell, Director, Policy<br />

and Public Affairs, Chartered <strong>Insurance</strong><br />

Institute (CII)<br />

MODERN INSURANCE | 7


INSIGHT<br />

A GUIDE TO THE NEW<br />

CONSUMER<br />

DUTY<br />

By now, I’m sure that everyone in the<br />

insurance industry will have heard<br />

about the new Consumer Duty. New<br />

regulations kicked off on 31st July<br />

2023, with the Financial Conduct<br />

Authority (FCA) going into overdrive<br />

to issue helpful guidance, letters - as<br />

well as playing host to a number of<br />

interesting podcasts and Q&As – in<br />

order to explain what’s needed.<br />

I, for one, welcome the new Consumer<br />

Duty. The Financial Services Authority<br />

commenced the regulation of General<br />

<strong>Insurance</strong> on 14th January 2005, and it<br />

all began with the principle of ‘Treating<br />

Customers Fairly’. This brief piece of<br />

commentary provides a springboard<br />

with which to further discuss my<br />

thoughts on the new Consumer Duty.<br />

Consumer Duty applies to everything that falls under FCA<br />

regulations – not just insurance, but also investments,<br />

mortgages, bank accounts, funeral plans, and so on. For<br />

insurance, this will be a progressive activity. However, for<br />

longer term policies, the new Consumer Duty will also apply<br />

in a retrospective sphere, and a ‘rear mirror’ approach will<br />

be needed to ensure compliance. In other words, does the<br />

product and service still work in the best interests of the<br />

consumer? Does it still provide fair value? This is a most<br />

interesting concept, but think of it like ongoing safety<br />

recalls on cars. Such evaluations can go on for several years<br />

in the event that a fault is discovered!<br />

So, if we have had the ‘Treating Customers Fairly’ principle<br />

for so long, why do we need to add a new principle, three<br />

cost cutting rules, and four outcomes?<br />

To refer back to the motor analogy, think of this as a very<br />

comprehensive instruction manual for a new car. It will<br />

show you how the product was made, how green it is, how<br />

everything works, what you need to do to enhance your<br />

driving experience, what happens if there is a blip… and<br />

then who you should address a complaint to! There will be<br />

copious detail included around design, assembly, testing,<br />

re-testing… the list goes on. Cars these days are incredibly<br />

complex, and likewise, insurance policies are hefty tomes.<br />

8 | MODERN INSURANCE


INSIGHT<br />

Now the FCA has tasked us all with a massive collective<br />

challenge – design your products right, make sure it works,<br />

provide evidence that it is understood by the consumer, and<br />

show everyone that it does indeed work through a seamless<br />

and transparent claims process.<br />

Back to the beginning, then…<br />

When an insurer or broker comes up with a bright idea,<br />

we need to create a product or service for a certain type<br />

of individual or business, one that will meet their exact<br />

needs. So, what does the insurer need to do to deliver this<br />

to market, with a huge focus simultaneously on the delivery<br />

of key outcomes? In other words, how are we going to put<br />

the thing together so it is ready for the road? And we will<br />

know that beforehand, as the road testing is integral to the<br />

design, building of the prototype, etc?<br />

The new principle is simple. “A firm must act to deliver good<br />

outcomes for retail customers.” Wait, I hear you ask. What<br />

are retail customers? We have been used to this definition<br />

since 2005 - it does include individual policies, but nothing<br />

considered as a ‘group’. SME business is included, but<br />

large corporate business is not – meeting the ‘Large Risk’<br />

definition instead. Why this doesn’t apply to everyone is<br />

beyond me, but anyway, I digress…<br />

Let’s focus on the four key outcomes…<br />

OUTCOME 1<br />

Products and services must be sold or<br />

provided at a fair price that reflects<br />

their benefits.<br />

This is a two-part equation. How has the insurer priced the<br />

product, and is that fair? Then, what services will the broker<br />

(and anyone else in the chain) provide, and is the payment<br />

they get for this sale (the commission) also fair? If you think<br />

this sounds like the Product Value Assessments that took<br />

place back in September 2022, you’d be right.<br />

If we go back to the car analogy, think of this as the<br />

collection of glossy booklets, plus a shed load of other stuff<br />

from the manufacturer. Is it a special scheme, has it cut<br />

down benefits, have excesses gone up, and are there any<br />

additions to enhance cover?<br />

OUTCOME 2<br />

Products and services that are fit for<br />

purpose - with terms and features that<br />

match the needs of the consumers<br />

they’re made for, and that work as<br />

expected.<br />

This is where the sharing of claims data is a must. Does<br />

the product actually work, and can the adviser use this to<br />

demonstrate efficacy to the prospective customer?<br />

Think of this as the test drive. Have we consulted with<br />

customers to gauge what they want, what works best for<br />

them, what’s important, and what’s less so? What is the<br />

customer prepared to pay for revolutionary new ideas?<br />

MODERN INSURANCE | 9


THE<br />

FUTURE<br />

OF NOW<br />

Our digital world continues to evolve, we are on a journey, changing customer engagement<br />

forever. Adapting to these new dynamics before the fact is essential, recognising the<br />

requirements of Claims and Collision 2.0 are business critical.<br />

Vizion remains at the forefront of the digital revolution<br />

with consistent pro-active focused innovation. Continually<br />

evolving to be future ready, in all areas of operation, ready to<br />

respond to changing customer and repairer needs, as well as<br />

developing solutions for new world challenges that continue<br />

to change and shape our industry.<br />

Technology should never be a blunt instrument, Vizion uses<br />

targeted utilisation of the right services at the right time to<br />

build greater customer engagement, providing convenience<br />

and accessibility for users to interact over the channels that<br />

they want to use at a time to suit them. Ensuring service<br />

delivery and consumer duty work seamlessly.<br />

New initiatives and benefits from group partners, such<br />

as Drive, Cornerstone and AutoFlow, bring even greater<br />

depth to the Vizion Network and our combined solution<br />

capabilities, accentuating and improving the customer<br />

experience.<br />

Hello future, we are ready, are you?<br />

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customers, and partners. To deliver industry leading services,<br />

dynamic business environments, focused on outcomes,<br />

through collaboration, expertise and technology. To provide<br />

true connected solutions, able to elevate the customer<br />

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future of the repair industry, today.<br />

www.vizionnetwork.co.uk/hellofuture


INSIGHT<br />

OUTCOME 3<br />

Consumers are equipped to make effective decisions.<br />

This involves presenting all of the necessary information at the right time in order to help the customer reach<br />

their informed decision. The adviser must assess the customer’s understanding, and check that the terms of<br />

the policy have been explained using clear and simple language.<br />

Bear in mind, advisers should be doing this as standard anyway! An adviser must advise, and NOT leave<br />

everything up to the customer to work out for themselves. <strong>Insurance</strong> terminology isn’t exactly easy to<br />

understand. Does this help the customer? Can definitions be made simpler, and how will you ascertain that<br />

customers understand what they’re buying?<br />

OUTCOME 4<br />

Helpful customer service.<br />

Is your customer service responsive and accessible? How easy is it for a policyholder to make changes,<br />

claim, complain, or cancel their policy? Don’t forget, a switch at renewal should always be in the very best<br />

interests of the customer, and not in the best interests of the adviser – someone who may well know that<br />

the firm gets much more commission at new business stage, rather than at the point of renewal.<br />

Did insurers square this off when they completed their Product Value Assessments? I hear some alarming<br />

statistics around claims calls taking well over an hour to answer, in comparison to new business calls<br />

taking less than a minute. Is that right?<br />

A quick update…<br />

On 20th September 2023, the FCA published further guidance calling on insurers to take action, warning<br />

that more steps must be taken to ensure good consumer outcomes.<br />

The FCA reminded insurers of its expectations, instructing the<br />

industry to review products to ensure that they are providing fair<br />

value to their customers.<br />

Matt Brewis, Director of General <strong>Insurance</strong>, said:<br />

“This is an early signal of the work we’ll be doing under the<br />

Consumer Duty. Customers should be reassured that we’re in<br />

their corner, and are taking action where we see poor value being<br />

provided.<br />

If the firms are unable to prove they’re providing fair value to their<br />

customers, they should expect further action from the regulator.”<br />

So, insurers have been warned, and I expect much more follow-up<br />

in the coming months. However, this does give the whole industry<br />

a huge opportunity to get things right. Product, price, value and<br />

service are the fundamental basics of insurance.<br />

<strong>Modern</strong>ise your<br />

communication with ATCX<br />

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MODERN INSURANCE | 11


INTERVIEWS<br />

DOING THE<br />

RIGHT THING<br />

As the insurance industry<br />

falls into step with<br />

new Consumer Duty<br />

regulations, <strong>Modern</strong><br />

<strong>Insurance</strong> <strong>Magazine</strong> sat<br />

down with Matt Brewis,<br />

Director of <strong>Insurance</strong> at<br />

the Financial Conduct<br />

Authority (FCA), to<br />

discuss preparations for<br />

the new guidance, the<br />

regulator’s key areas of<br />

focus at the moment, and<br />

the associated challenges<br />

faced by the industry in<br />

relation to adoption and<br />

compliance.<br />

Hi Matt, thanks so much for your time today!<br />

Q This edition of <strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong> focuses on the<br />

new Consumer Duty, which came into effect for existing<br />

products and services on 31st July 2023. How does your<br />

role specifically focus on an industry understanding of<br />

these new requirements?<br />

A<br />

I’m responsible for overseeing regulation within the full<br />

insurance ecosystem. Every part of the market has its own<br />

unique set of operations, with different roles to adopt<br />

when it comes to bringing new rules into force. General <strong>Insurance</strong>,<br />

for example, saw the introduction of the <strong>Insurance</strong> Distribution<br />

Directive in 2018, the key components of which form part of our<br />

new Consumer Duty.<br />

Arguably, this area of the sector has had plenty of time to get their<br />

head around what we’re doing here in comparison to other areas of<br />

financial services. My role has involved preparing the team for the<br />

implementation of the new Consumer Duty, as well as guiding the<br />

industry as much as possible when it comes to our own priorities<br />

under the new regulations. We’ve done this through thematic<br />

reviews, keynote speeches and interviews, published guidance, Q&A<br />

sessions - you name it! We’re aiming for complete transparency<br />

in our instruction and direction, particularly when it comes to<br />

addressing areas where we want to see the most improvement.<br />

Q<br />

A<br />

I know that your team spent a large part of last year<br />

carrying out thematic reviews ahead of the regulations<br />

coming into place. What were the standout areas of<br />

this work?<br />

Yes, on the back of these thematic reviews, our latest set<br />

of publications informs the industry of our key focus and<br />

priorities. ‘Fair value’ is a standout area and key theme<br />

running throughout all areas of our new guidance. Do the products<br />

on offer truly make sense for consumers?<br />

We’ve still found weaknesses, despite focusing some of our reviews<br />

on existing Product Governance rules - as opposed to the new<br />

Consumer Duty, which is, of course, one step further. That’s why our<br />

focus on ‘fair value’ continues to be emphasised. Take Guaranteed<br />

Asset Protection (GAP) insurance as one example. Our stance<br />

asks insurers to question whether the product on sale genuinely<br />

offers value to the consumer, when a disproportionate amount of<br />

premiums received frequently contribute to sales commission.<br />

When we start to consider life insurance, service standards<br />

and transformation are also core issues for us. Many firms are<br />

12 | MODERN INSURANCE


INTERVIEWS<br />

WITH MATT BREWIS<br />

consolidating their books and outsourcing this type of work;<br />

we’ve seen cyber incidents in some cases, which has naturally<br />

had a significant impact on customers. We’ve also seen service<br />

standards drop when firms have been migrating data, resulting in<br />

claims taking longer than usual to pay out and affecting vulnerable<br />

customers who are in the process of grieving the loss of a loved<br />

one.<br />

We’re pushing firms on all of these areas, and demonstrating where<br />

we want to see improvements made. The recent intervention we’ve<br />

taken towards GAP insurance is really the first example of the type<br />

of action that the industry is going to see more of. We’ve got a<br />

whole range of tools that we can use to act against firms who don’t<br />

comply, and I hope these consequences will move the market in the<br />

right direction and show that we’re serious about these changes in<br />

the long term.<br />

Back in Spring, the FCA specifically commissioned<br />

an anonymous survey of 1,230 firms to establish the<br />

Q industry’s preparedness and attitudes in respect of the<br />

new Consumer Duty. What were your key findings from<br />

this, and how do those compare with reality now that the<br />

new Consumer Duty has come into play?<br />

A<br />

The FCA supervise around 55,000 firms, and so we’re<br />

somewhat outnumbered when it comes to being able<br />

to spend an adequate amount of time with each one!<br />

Therefore, the purpose of this survey was to ascertain preparedness<br />

for the Consumer Duty from smaller firms specifically. We did this<br />

anonymously and via a third party to encourage honesty.<br />

The adoption of the new Consumer Duty is a gradual journey;<br />

even some of the big firms are still embedding it. We need to keep<br />

pressing in order to push for these higher standards. The results of<br />

the survey indicated that 64% of firms would be fully compliant by<br />

the July deadline, with 23% displaying confidence that they would<br />

be mostly compliant by this time. I don’t believe these figures<br />

reflect the reality we’re faced with at the moment, and that’s why<br />

it’s really important for us to keep pushing. We’re dedicated to<br />

identifying firms that are defying the regulations. Some firms are<br />

nearly there; some are burying their heads in the sand, and part of<br />

our task right now is to find them.<br />

How have the FCA supported firms in addressing pressure<br />

points and challenges?<br />

Q<br />

A<br />

Well, when it comes to those firms who are really trying,<br />

we’re happy to give as much guidance as possible to ensure<br />

they get it right. The aforementioned example of GAP<br />

insurance illustrates this point; regulation for General <strong>Insurance</strong><br />

has been in place for years already. Low value products that exist<br />

more for the financial gain of the distribution chain are a problem,<br />

and often delivered at the consumer’s expense. Our latest letter<br />

addressing this is full of examples of products that we don’t like the<br />

look of, and we’re perfectly clear in our explanation of how we’d<br />

like insurers to address these issues - as well as details of what the<br />

consequences will be if they don’t.<br />

We’ve also taken time to highlight our concerns around<br />

Premium Finance, and the ‘poverty premium’ which profits from<br />

policyholders who are unable to pay their annual premium upfront.<br />

Consumers should not have to pay 30% more for their car or home<br />

insurance if they have to pay monthly, and we’ve made our stance<br />

Matt Brewis,<br />

Director of <strong>Insurance</strong> at the Financial<br />

Conduct Authority (FCA)<br />

on that perfectly clear in our latest guidance. Where cars have been<br />

written off, we’ve identified instances where a number of firms<br />

have been paying out claims that do not cover the full value of the<br />

car, and they are now being forced to make reparations for this in<br />

retrospect. Executives that commission internal reviews to identify<br />

and combat these issues within their own claims departments are<br />

displaying the right behaviour, and I would recommend that others<br />

should follow suit.<br />

Q<br />

The obligation to act in ‘good faith’ has been the cause of<br />

much comment in the lead-up, and also in the delivery of<br />

these new regulations. Is there now widespread clarity in<br />

terms of the way that this is being interpreted, or is this<br />

aspect still a work in progress?<br />

Whilst the rules are clear, of course there’s potential for<br />

discrepancy in how these are interpreted. Some people<br />

A prefer to work to general principles and others want to know<br />

the exact boundaries for compliance, so as a regulator, it’s difficult<br />

to find a balance that suits everyone.<br />

I think this is one of those areas where case law is going to build<br />

up over time. I know how I interpret the guidance, and the basic<br />

sentiment really just involves putting the best interests of the<br />

customer at the heart of all products and services. We want to<br />

achieve the right outcome for customers on every occasion. We’ll<br />

continue to work closely with the Financial Ombudsman, and they<br />

will still be adjudicating complaints as we follow up with individual<br />

firms. This will build a precedent as we move into the new era of<br />

Consumer Duty. The basic message: do the right thing by your<br />

customers. Would you buy this product as it exists in its current<br />

form, and if not, what are you doing selling it?<br />

Q<br />

A<br />

The FCA has introduced Principle 11 of the new Consumer<br />

Duty, which requires firms to notify you if they become<br />

aware of an organisation within the distribution chain<br />

that does not comply with the new regulations. Whilst<br />

the principal of this works in theory, how will the FCA be<br />

upholding this in practice?<br />

Whistleblowing and intelligence from firms will always be<br />

received confidentially, and in many ways, we do rely on<br />

this type of information when it comes to enforcement.<br />

There are regulated elements of the distribution chain juxtaposed<br />

with other aspects, like Credit Hire, which fall outside of this remit.<br />

However, insurers and brokers choose to work with these firms<br />

and control how that chain of distribution works. If behaviour from<br />

an unregulated firm is problematic and not compliant with the<br />

Consumer Duty, it still falls to the insurer to take ownership of that<br />

process.<br />

One of the key regulatory components involves the avoidance of<br />

creating foreseeable harm in products and services, and Credit<br />

Hire is a clear-cut example. Outsourcing claims services to an<br />

unregulated industry and passing the buck won’t make the problem<br />

go away; it’s really important that this issue is dealt with to maintain<br />

the principle of acting in good faith. Every part of the distribution<br />

chain should be working together to achieve this mutual goal, and<br />

anything else is simply bad for business.<br />

MODERN INSURANCE | 13


INTERVIEWS<br />

<strong>Modern</strong> <strong>Insurance</strong><br />

<strong>Magazine</strong> recently<br />

sat down with<br />

Sam Richardson,<br />

Deputy Editor<br />

of Which?<br />

Money, to query<br />

the ‘consumer’<br />

aspect of the new<br />

Consumer Duty.<br />

How does the<br />

general public<br />

perceive insurance,<br />

and can these new<br />

regulations make a<br />

positive impact in<br />

the long term?<br />

with Sam Richardson,<br />

Which? Money<br />

Sam – drawing upon your<br />

experience at Which? Money,<br />

Qwhat does the current relationship<br />

between consumers and insurers<br />

look like to you?<br />

A<br />

We survey home and car insurance<br />

customers who have made a<br />

claim within the last one or two<br />

years. Almost all of those customers have<br />

reported satisfaction on these surveys;<br />

90% of home insurance claimants and<br />

93% of car insurance claimants are happy<br />

with the overall service received from their<br />

insurance provider.<br />

I’m sure you’ll agree that this is really<br />

encouraging, but the fact that this<br />

feedback comes from claimants is<br />

certainly worth noting. Where customers<br />

haven’t needed to submit a claim, we’re<br />

seeing plenty of irritation around price<br />

rises and claims inflation right now. It’s a<br />

matter that is really testing patience, and<br />

customers are struggling to see the value<br />

in their premiums - especially where those<br />

price rises end up significantly higher<br />

than the standard rate of inflation. Some<br />

aspects of this are explainable, but there’s<br />

little we can do to provide the necessary<br />

comfort to those with the highest rise in<br />

the cost of their premiums.<br />

Oftentimes, we’ve also found that if<br />

something goes wrong in the claims<br />

process, it goes very wrong. We’ve<br />

heard examples of many home insurance<br />

customers having to chase their insurer on<br />

multiple occasions, alongside reports from<br />

three quarters of car insurance customers<br />

to say that they weren’t offered a suitable<br />

explanation when their claim was rejected<br />

or only partially accepted. On top of<br />

this, there’s the General <strong>Insurance</strong> Value<br />

Measures from the Financial Conduct<br />

Authority (FCA), highlighting pretty<br />

poor payout rates from home and travel<br />

insurance providers across the board.<br />

This creates a general sense of scepticism<br />

between consumers and insurers, and<br />

seemingly, it has been that way for many<br />

years.<br />

What’s the most common<br />

grievance that consumers<br />

Q report to Which? in relation to<br />

insurance?<br />

Anecdotally, most of the<br />

complaints we’re seeing are around<br />

A the subject of price rises, in some<br />

cases addressing inexplicably huge jumps<br />

in premiums without much reasoning<br />

given as to why this was necessary. In<br />

claims, our surveys indicate that the main<br />

areas of dissatisfaction address delays<br />

with the speed of settlement, the lack of<br />

support provision in place from insurers,<br />

and poor communications around the<br />

status of a claim.<br />

With this in mind, how do you<br />

expect to see the new Consumer<br />

QDuty alter the reputation of the<br />

insurance industry over time?<br />

Insurers have been subject to high<br />

levels of scrutiny for many years,<br />

A including some changes to Product<br />

Governance rules in General <strong>Insurance</strong><br />

back in 2021. I’m confident that we’ll see<br />

some improvements in the long-term,<br />

and while better outcomes won’t happen<br />

overnight, when we think about the<br />

potential for longevity within these new<br />

regulations, I’m sure that we’ll see some<br />

developments in consumer satisfaction as<br />

the new Consumer Duty takes hold.<br />

At the moment, we’re seeing a high<br />

number of complaints to the Financial<br />

Ombudsman Service (FOS), of which<br />

a lot are upheld. I would say that<br />

improvements in insurance products<br />

and processes specifically will result in a<br />

consequent handling of those complaints<br />

internally, namely in a way that doesn’t<br />

14 | MODERN INSURANCE


INTERVIEWS<br />

involve the FOS so much moving forward.<br />

The FCA are predicting a short-term spike<br />

in complaints as the new regulations settle<br />

in, followed by a reduced number once the<br />

new Consumer Duty hopefully starts to<br />

mitigate issues for potentially vulnerable,<br />

high risk or dissatisfied customers.<br />

Ultimately, it’s up to the FCA to step<br />

up and enforce these new rules, and on<br />

behalf of consumers, we want to see real<br />

penalties for those who do not comply.<br />

Which? was extensively<br />

involved in consultation as the<br />

Q new Consumer Duty was being<br />

developed. Tell me more about<br />

this process, and what was<br />

involved.<br />

A<br />

Indeed, our Policy Team worked<br />

really closely in consultation with<br />

the FCA to form the basis of the<br />

new Consumer Duty through regular<br />

discussions and collaboration. We’re very<br />

much in support of it now; admittedly,<br />

there was some concern at first around<br />

the width of ambition behind the new<br />

regulations, but we clearly see the FCA’s<br />

commitment and dedication to industry<br />

reform. It supports a lot of what Which?<br />

is all about, the idea of fair treatment as<br />

default.<br />

On that topic then, how are<br />

Which? hoping to raise awareness<br />

Q of the new Consumer Duty in<br />

order to educate insurance<br />

customers about their rights<br />

moving forward?<br />

A<br />

I’m sure we’ll be writing frequently<br />

about the Consumer Duty as these<br />

new regulations take hold. Where<br />

we identify insurers or those within the<br />

distribution chain that don’t comply, we’ll<br />

also be referencing the Consumer Duty<br />

and highlighting where a particular insurer<br />

has fallen short of their obligations. From<br />

the perspective of our readership, we<br />

need to keep reminding them that the<br />

Duty exists for their benefit. <strong>Insurance</strong><br />

is a topic that we cover in each issue of<br />

Which? Money magazine, so of course we<br />

need to cover the Consumer Duty as part<br />

of our commentary.<br />

We also cover complaints to insurers in<br />

our various online guides. Currently,<br />

these address the process of<br />

making and escalating a<br />

complaint, but I’m sure we’ll<br />

be building on this advice<br />

with more focus on the<br />

Consumer Duty moving<br />

forward.<br />

Ultimately, however, rules<br />

are for providers to follow.<br />

It shouldn’t fall on the<br />

consumer to adopt the<br />

endless role of identifying a<br />

lack of compliance; that job<br />

falls to the regulator, and<br />

also to us to a slightly lesser<br />

extent. Of course we want<br />

our readership to understand the basics,<br />

but in this case, compliance falls firmly on<br />

the shoulders of those responsible.<br />

What impact might the new<br />

Consumer Duty have on the<br />

Q number of complaints in the short<br />

and long term?<br />

We’ve already touched on this<br />

slightly, in that I know the FCA<br />

A were expecting to see an initial<br />

spike in the number of Consumer Duty<br />

complaints before reaching an eventual<br />

plateau. On the other hand, the FOS have<br />

said that they can already judge the level<br />

of complaints based on reasonable, fair<br />

standards, so they don’t seem to predict<br />

the same upturn.<br />

I don’t foresee an immediate change in the<br />

short term either, but time will tell. We’ll<br />

still continue to refer people through to the<br />

FOS and see how things go. Sometimes<br />

there are delays, and if this happens, we’ll<br />

work with them to find another way of<br />

handling volume.<br />

Q<br />

More generally speaking, how long<br />

do you think it will be until we see<br />

a major shift in consumer trust and<br />

confidence?<br />

Some of the issues we’re seeing<br />

have been around for years. We’re<br />

A working on an editorial piece at the<br />

moment looking into the standards of loss<br />

adjusters in home and property claims,<br />

and I suspect that issues in this area of the<br />

industry will take a fair while to rectify. If<br />

inflation starts to come down next year,<br />

it will also be interesting to see whether<br />

premiums fall as a consequence.<br />

With dreadful savings account interest<br />

rates, for instance, we saw politicians get<br />

involved and the issues are being rectified<br />

quickly. Unfortunately, I’m not sure that<br />

the same can be said for insurance. Bad<br />

behaviour has a habit of living on in the<br />

memory of consumers for a while - not so<br />

much related to General <strong>Insurance</strong> per se,<br />

but I do think people are going to be very<br />

cynical about the industry for quite a long<br />

time to come.<br />

Car insurance is another great example.<br />

It’s still a grudge purchase and not a<br />

much-loved product, and yet it has higher<br />

payout rates than many other lines of<br />

insurance at around 99%. We’re dedicated<br />

to making sure that consumers obtain a<br />

product which actually works, especially<br />

when there are so many other cost-ofliving<br />

pressures at the moment. We need<br />

to see insurers offering fair value at a fair<br />

price.<br />

QFinally, looking ahead, what<br />

research will Which? conduct in<br />

future to assess the efficacy of the<br />

new Consumer Duty in insurance?<br />

AWe’ll continue to take a balanced<br />

approach by conducting deep<br />

research into the policy side of<br />

the new Consumer Duty, one that informs<br />

regulators and other governing bodies.<br />

We also have the editorial side, which<br />

informs consumers. Every year, we run<br />

Customer Satisfaction surveys for car<br />

and home insurance, sometimes for pet<br />

and travel insurance as well. We also pay<br />

very close attention to General <strong>Insurance</strong><br />

Value Measures, and submit a number of<br />

Freedom of Information requests to the<br />

FOS to ‘name and shame’ when we’re<br />

investigating specific complaints further.<br />

I think we’ll follow a similar approach for<br />

matters related to the Consumer Duty, as<br />

insurance is now one of our priority areas.<br />

We’re particularly interested in pricing,<br />

and how insurers are coming up with<br />

their prices in an ethical, fair and balanced<br />

way, particularly in light of increased<br />

automation within the underwriting and<br />

risk assessment process.<br />

Sam Richardson,<br />

Deputy Editor, Which? Money<br />

MODERN INSURANCE | 15


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EDITORIAL BOARD<br />

Preparing Teams for the<br />

New Consumer Duty<br />

The new Consumer Duty requirements for General<br />

<strong>Insurance</strong> is a significant shift in regulatory<br />

expectations. It introduces a more outcomes-focused<br />

approach to consumer protection, and sets higher<br />

expectations for the standard of care given to<br />

customers.<br />

The Financial Conduct Authority (FCA) want good outcomes<br />

for customers to be at the heart of firms’ strategies and business<br />

objectives, and leaders have a key role to play here. Firms’ boards and<br />

senior management should embed the interests of customers into<br />

their culture and purpose.<br />

Here at Carpenters Group, our values are fully aligned to delivering<br />

a first-class claims experience. We understand that it is paramount<br />

to our customers and our insurer partners that we deliver when the<br />

customer needs us most – at the point of claim.<br />

Our long-standing relationships are a testament to the quality of our<br />

service. Our focus is always on the customer, ensuring a claims journey<br />

that consistently exceeds expectation.<br />

Carpenters Group have been preparing for the new Consumer Duty<br />

for some time, building on the strong foundation of our customer<br />

focused strategy. This already includes constant training to ensure<br />

that we are treating all customers fairly, along with our more specific<br />

training for vulnerable customers in particular. We have adapted<br />

our training regime to include Consumer Duty specific training to all<br />

colleagues, supporting their understanding of the changes and what<br />

this means to the various teams across the business.<br />

We continue to work collaboratively with our insurer clients to<br />

ensure that we represent their brand in the best possible light, by<br />

communicating with customers in a way that effectively meets the<br />

differing requirements of our insurer clients.<br />

Identifying vulnerability has always been a part of the Carpenters<br />

Group customer journey, and this has not changed. We promote an<br />

agile and adaptive approach, long recognising that ‘one size does not<br />

fit all’.<br />

We are closely linked to our insurers with regards to data and<br />

reporting requirements, and remain happy to discuss the industry’s<br />

wider needs with regards to reporting and agreeing a standard set of<br />

MI, one that all parties involved in the customer journey can subscribe<br />

to.<br />

Paul Challoner,<br />

Commercial Director, Carpenters Group<br />

The New Consumer Duty:<br />

A Change in Distribution<br />

The new Consumer Duty rules will set ‘higher<br />

and clearer standards of consumer protection’<br />

for the insurance industry. While many firms will<br />

already have the new rules enshrined in their<br />

operations, securing consumer protection during<br />

the distribution journey brings its own unique set of<br />

challenges, and should not be neglected.<br />

During B2C digital journeys, customers must fend for themselves<br />

as they navigate the online infrastructure of the business they are<br />

engaging with. Many B2C journeys are optimised around new business<br />

generation, but Consumer Duty requires firms to make a product’s<br />

cancellation process just as simple as the purchase process.<br />

There are several ways that firms can achieve this, one of which is<br />

to offer an end-to-end digital portal that allows clients to log in and<br />

make changes themselves. Some firms will struggle with this from a<br />

technical perspective and a cost perspective, and this solution will<br />

not suit everyone. Quite rightly, many firms will want to speak to the<br />

client before they make changes to their policy, particularly during<br />

the cost-of-living crisis when clients might be tempted towards<br />

underinsurance. To support this, firms need to make their online<br />

environment clear - complete with instructions that detail how clients<br />

can amend or cancel their policies, and with obvious signposting to<br />

guide clients in the right direction.<br />

Brokers and MGAs/insurers may also have to communicate with<br />

clients in new ways. The FCA has identified good practice for MGAs/<br />

insurers, asking them to contact clients directly (even when a<br />

broker controls the relationship) to establish whether the product is<br />

appropriate, particularly when there is a possibility that the client is<br />

vulnerable in some way.<br />

This is challenging for brokers and MGAs/insurers in two ways. Firstly,<br />

the MGA/insurer would not necessarily have contact details for their<br />

clients if the business was brokered, and the infrastructure may not<br />

be in place to allow this to be shared between both parties. Secondly,<br />

the idea of an MGA/insurer contacting a client directly will be<br />

anathema to many brokers, and quite likely prohibited by the existing<br />

agreements in place between them.<br />

However, innovative brokers and MGAs/insurers are likely to be able<br />

to find a strong solution to this challenge. Many may see it as an<br />

opportunity to engage with clients on a joint basis, and in a manner<br />

that not only satisfies the requirements of Consumer Duty, but also<br />

strengthens the operations of their respective brands.<br />

Will Prest,<br />

Product Manager, ParaCode<br />

MODERN INSURANCE | 17


EDITORIAL BOARD<br />

Supporting Insurers with their<br />

Consumer Duty obligations<br />

At the end of July, insurers were required to<br />

implement the FCA Consumer Duty rules for<br />

new and existing products and services for sale<br />

or renewal. Significant process re-engineering<br />

and monitoring continues to be necessary to<br />

reflect and fulfil the regulations. In the claims<br />

environment, we believe that service delivery from<br />

external providers must align with insurer strategy<br />

and procedures to meet the FCA requirements.<br />

At e2e, we help our insurer clients to help their customers and, in<br />

doing so, we are an important part of the Consumer Duty distribution<br />

chain. Our job is to satisfy our clients’ needs and, nowadays, this<br />

necessitates an awareness of their responsibilities under Consumer<br />

Duty. We regard ourselves as the supportive arm of an insurer,<br />

who must fulfil the requirements of Consumer Duty principles and<br />

practices in turn.<br />

A total loss motor claim is a stressful situation for insurance<br />

customers. As experts in total loss vehicle management, we add<br />

value for our insurer clients, and for their customers as a result.<br />

Our professional contact centre delivers a high-quality customer<br />

experience, and can supplement the insurer role where needed.<br />

Clear communication is our priority, including careful and appropriate<br />

management of vulnerable customers. The loss of a vehicle means<br />

different things to different customers, and we treat each situation<br />

individually with empathy and understanding. This ranges from<br />

collecting the vehicle, which in some cases will be directly from the<br />

policy holder, to carefully packaging and returning personal effects<br />

which may have been left in the vehicle. We ensure all personal<br />

information is removed from infotainment systems, giving customers<br />

confidence that their personal data is securely handled in line with<br />

GDPR requirements. Reflecting different customer needs, we also<br />

offer specific services for cherished plates and classic cars.<br />

We help to move vehicles swiftly through the claims life cycle,<br />

providing swift, accurate engineering assessments to determine<br />

whether a borderline vehicle is repairable or a total loss. Access to our<br />

network’s comprehensive 0.5M stocks of quality-graded, warrantyassured<br />

reclaimed parts means our insurer clients can offer choices<br />

to their customer. In many cases, it can become economically viable<br />

to repair a borderline total loss vehicle with reclaimed parts. Where a<br />

vehicle is a total loss, we accurately represent the insurer philosophy,<br />

negotiating settlement where required using insurer guidelines in line<br />

with ‘fair value’. Furthermore, we have invested in a state-of-the-art<br />

auction platform, enabling us to further maximise salvage auction<br />

returns. This also facilitates the insurer in supporting the customer<br />

and offering ‘fair value’ when a settlement is being determined.<br />

Our role is far greater than the provision of salvage services; it<br />

encompasses the management of customer loss. Our insurer clients<br />

trust us to get it right, reflecting their Consumer Duty strategy and<br />

boosting their reputation. At e2e, it’s a role we truly relish.<br />

Jim Loughran,<br />

CEO, e2e Total Loss Vehicle Management<br />

Mitigating the Effects<br />

of Rising Claims Costs<br />

The motor insurance market is under immense<br />

pressure from claims inflation. Labour costs<br />

are up by 40%, and vehicle repair costs have<br />

risen by 33% 1 . For every £1 that motor insurers<br />

received in premiums, £1.10 in claims and<br />

operating costs were paid out in 2022 2 .<br />

However, motor insurance providers can claw back some control<br />

through effective use of the latest data enrichment solutions.<br />

Innovations in vehicle, person and place data delivered through one<br />

gateway can help them understand the risk of a claim and how much<br />

that claim could cost, to a high degree of accuracy.<br />

Take vehicle centric data as an example. It is now possible to build<br />

an immediate and granular picture of the history and value of a<br />

vehicle - as well as the risk related to how well that vehicle has been<br />

maintained - through LexisNexis® Vehicle Insights. The beauty of this<br />

data enrichment solution is that it can be used in tandem with unique<br />

information on vehicle build (via LexisNexis® Vehicle Build) to identify<br />

the presence and performance of Advanced Driver Assistance Systems<br />

(ADAS) features for that specific vehicle. Therefore, insurance providers<br />

can instantly understand the features that the vehicle was ‘born’ with,<br />

its life after leaving the production line, and what that means from a<br />

risk perspective.<br />

<strong>Insurance</strong> providers can then incorporate predictive information on the<br />

drivers/additional drivers of the vehicle (such as their policy history)<br />

through solutions such as LexisNexis® Policy Insights. For example, past<br />

cancellations can equate to 70% higher loss cost, and an individual<br />

with multiple NCD entitlements at any one time has a 33% higher loss<br />

cost. In addition, individuals with gaps in cover have a 55% increased<br />

likelihood of cancelling a policy mid-term 3 .<br />

A cross-market view of claims history for the car or home as well as<br />

the individual through LexisNexis® Precision Claims offers immense<br />

predictive potential. This is really evidenced in U.S. analysis 4 , which<br />

shows that people with three or more motor claims incur home claims<br />

losses that are approximately 40% higher in cost than those without<br />

any motor claims.<br />

The next step could be to bring in more detailed information about the<br />

property using geospatial data intelligence to understand theft risk,<br />

and indeed garaging and/or parking at the address.<br />

There are many factors involved in understanding motor insurance risk,<br />

but by using one gateway to some of the market’s most powerful data<br />

enrichment solutions, insurance providers can make more informed<br />

decisions that could help to mitigate the rising cost of claims.<br />

Tom Lawrie-Fussey,<br />

senior director of product management, U.K and Ireland,<br />

LexisNexis Risk Solutions<br />

1 https://www.abi.org.uk/news/news-articles/2023/8/sustained-cost-pressures-oninsurers-push-the-average-price-of-motor-insurance-to-a-record-high/#:~:text=The%20<br />

average%20premium%20paid%20for,this%20data%20back%20in%202012.<br />

2 https://www.ey.com/en_uk/news/2023/06/ey-uk-motor-insurance-results-analysis<br />

3 Based on LexisNexis Risk Solutions Analysis<br />

4 Based on LexisNexis Risk Solutions internal studies of U.S. personal lines claims histories<br />

MODERN INSURANCE | 19


EDITORIAL BOARD<br />

Embracing the<br />

New Consumer Duty<br />

Here at National Windscreens, we welcome<br />

the introduction of Consumer Duty from the<br />

FCA. It serves to further reinforce our duty of<br />

care to the customer. Providing a first-class<br />

service has always been our priority, and this<br />

has embedded best practices throughout the<br />

organisation even before the regulations were<br />

introduced in July.<br />

As a result of the Consumer Duty, we have established even closer<br />

relationships with our insurance partners to further collaborate<br />

and align our services. National Windscreens has always sought<br />

to provide a personalised and transparent service, and with the<br />

introduction of Consumer Duty, we re-assessed our policies<br />

and reaffirmed the need for positive and clear interactions with<br />

policyholders.<br />

We have become increasingly focused on collecting the right insights<br />

to help us care for our customers in the future, especially around<br />

vulnerabilities. We understand that recruiting motivated people<br />

and developing them as engaged employees will guarantee good<br />

customer outcomes.<br />

As we are customer-centric, we have invested heavily in our<br />

communication strategies to meet the convenience of the<br />

policyholder. Our digital team has worked incredibly hard to establish<br />

an award-winning customer journey; a robust process that was<br />

created following rigorous feedback programmes in collaboration<br />

with our valued insurance partners.<br />

On the day of the appointment, the policyholder can track the<br />

progress of the technician as they make their way to the venue,<br />

enabling the policyholder to anticipate the technician’s arrival and<br />

manage their day effectively.<br />

We fully utilise Trustpilot to better understand the perspective<br />

and experience of our customers, helping us to constantly review<br />

and shape our proposition, and ensuring that communication with<br />

customers continues to be effective and accessible. Crucially, in the<br />

instances where our high standards have not been met, we conduct<br />

an immediate investigation to address the incident.<br />

We want to continue improving the customer experience with both<br />

digital and traditional routes by incorporating additional signposting<br />

for vulnerable customers, all with the goal of creating exceptional<br />

service.<br />

We have also embraced technology to welcome the new Consumer<br />

Duty. We use a bespoke, in-house system to manage the first notice<br />

of loss (FNOL), validation, and the most appropriate booking for the<br />

policyholder. This system logs the job from the initial contact, right<br />

through to completion.<br />

We also use Vodafone Storm, which allows omnichannel<br />

communication between phone, email, chat and text. This manages<br />

timely communication with the policyholder in line with their<br />

preferences. Vodafone Storm is used by the emergency services and<br />

is therefore very dependable under pressure, with 99.99% reliability.<br />

This system brings all channels into a single, cloud-based platform,<br />

with the capability to future proof the needs of the policyholder<br />

through AI as they evolve over time.<br />

Simon Hunt,<br />

Commercial & Services Director, National Windscreens<br />

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MODERN INSURANCE | 21


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EDITORIAL BOARD<br />

BASF UK x STEM:<br />

Curiosity and Creativity<br />

Earlier this year, young learners at St Matthew’s<br />

Primary School, Stockport enjoyed a week of<br />

science-based experiences and experiments,<br />

supported by a team of volunteers from BASF,<br />

the world’s largest chemical company.<br />

Throughout the week, 27 BASF STEM Ambassadors hosted 11<br />

interactive sessions, bringing the breadth of science to life, and asking<br />

the children to consider what it is to be a scientist. The activities on<br />

offer aimed to stimulate an interest in science, fostering curiosity and<br />

creativity.<br />

Highlights included worm-charming to investigate soil health,<br />

designing innovative car colours through BASF Colour Lab, learning<br />

how drones work, creating an indoor planetarium, and exploring food<br />

technology by making chocolate mousse!<br />

It was great to see all the pupils at St Matthew’s Primary School get<br />

involved in STEM week. Year on year, we see just how vital it is for<br />

us to do our part within the community in order to inspire the next<br />

generation of painters. The activities we ran this year have STEM<br />

learning at their heart, ultimately designed to encourage pupils to<br />

be inquisitive about the world around them. It was amazing to see<br />

so many pupils join in, asking questions about different colour mixes<br />

and quizzing the volunteers to see what inspired them to work in our<br />

industry in the first place.<br />

We also took the opportunity to select the most inimitable of the<br />

custom colours mixed by the pupils, and brought their designs to life<br />

using our all new Glasurit 100 Line basecoat line. Sustainable initiatives<br />

add value to our brand, so when brands like Glasurit showcase its<br />

innovations - and in a way that can be adapted to suit a young<br />

audience - it signals to future painters and prospects that we care.<br />

Clearly, for us, sustainability is far more than just ‘going green’. When<br />

even the next generation of painters are on board, that’s what success<br />

looks like for us.<br />

“A week like this has a massive impact on our pupils,” commented<br />

Faye Garner, Science Lead at St Matthew’s Primary School. “They get<br />

to experience things they normally wouldn’t, and the BASF STEM<br />

ambassadors have been inspirational.”<br />

The relationship with St Matthew’s Primary School will continue, as the<br />

BASF STEM Ambassadors are keen to support science learning and<br />

help the school to redevelop their outdoor garden space.<br />

At BASF, we create chemistry for a sustainable future.<br />

Dr. Natalie Wong,<br />

Marketing & Portfolio Management Lead,<br />

BASF Automotive Refinish UK & Ireland<br />

Has the ‘as-a-Service’ trend<br />

arrived in the claims industry?<br />

Software-as-a-Service (SaaS) hit the big time<br />

in the early 2000s, and since then, the ‘as-a-<br />

Service’ model has made its way into many other<br />

industries. ‘As-a-Service’ is a tried and tested<br />

way of providing a flexible service offering. It’s<br />

a scalable solution that reduces initial outlay,<br />

allowing businesses and individuals to draw on a<br />

service as and when they need it.<br />

It’s extremely common in the software space. You’ve probably<br />

heard of Mobility-as-a-Service (MaaS), which aims to bring multiple<br />

transport options together on a single platform.<br />

In the insurance industry, there’s a growing interest in ‘Claims-as-a-<br />

Service’ - on demand access to services like FNOL and third-party<br />

intervention. This allows insurers and MGAs to effectively handle<br />

peaks in demand, or bolster in-house capacity without investing<br />

in additional, permanent resources. Advances in technology and<br />

system connectivity mean that more businesses can take advantage<br />

of flexible, outsourced services as part of their claims strategy. The<br />

benefit is the ability to scale services quickly, and deliver great<br />

outcomes at the point of claim.<br />

Could ‘as-a-Service’ solutions be used in other areas of the claims<br />

supply chain?<br />

In motor claims, long-term challenges - including a shortage of<br />

repair capacity and parts delays - are placing traditional vehicle<br />

repair strategies under pressure. According to Trend Tracker’s Market<br />

Snapshot Report, available repair capacity has fallen, while demand<br />

for vehicle repairs increased by 23% over the last 12 months.<br />

To counter these challenges, insurers need a more dynamic repair<br />

solution, one that complements their existing capabilities. Repair-as-a-<br />

Service could very well be the answer - a solution that offers insurers<br />

direct access to vehicle repair slots, with no minimum deployment<br />

required. The flexibility to deploy as many or as few vehicles as needed<br />

to a repairer at any time, in any location, and at varying levels as<br />

demand fluctuates.<br />

It’s an offering with the potential to support insurers in relieving repair<br />

backlogs that are affecting certain location or vehicle types, or as<br />

overflow to support day-to-day operations. Like other ‘as-a-Service’<br />

offerings, Repair-as-a-Service includes value-added options like<br />

engineering, triage, and repair management, which can also be utilised<br />

on demand. This allows insurers to pick and choose the services they<br />

need most, creating a repair partnership that works for them and<br />

adapts to their changing requirements.<br />

Repair-as-a-Service could address anything, from straightforward<br />

overflow capacity to a fully-fledged accident management partnership<br />

that encompasses the whole repair management process. When we<br />

look at the challenges facing the motor claims industry, it seems clear<br />

that increased flexibility could offer significant benefits.<br />

‘As-a-Service’ models can be a fantastic tool when developing a claims<br />

strategy, and a real benefit in building a robust repair solution to<br />

reduce repair times and hire costs.<br />

Head to activate-group.com/repair-as-a-service if you want to find out<br />

more.<br />

Lorna Turner,<br />

Director of Business Development, Activate Group<br />

MODERN INSURANCE | 23


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EDITORIAL BOARD<br />

Providing Fair, Flexible<br />

and Inclusive Services<br />

Since 2015, the Financial Conduct Authority<br />

(FCA) has urged the financial sector to<br />

offer extra support for customers in need of<br />

additional care, formerly known as ‘vulnerable<br />

customers’. However, circumstances can be<br />

wide-ranging and complex, leading to an<br />

individual or their family needing further<br />

assistance adjacent to that of their insurance<br />

claim.<br />

The pandemic changed everything for some people, and our eyes<br />

have been opened to the broader issues that may affect a person’s<br />

ability to understand and navigate the claims process. Someone<br />

who didn’t need additional support at the outset of the pandemic<br />

may have since experienced a loss of income or bereavement, stress<br />

or loneliness - factors that may now leave them anxious or hesitant<br />

to communicate. Furthermore, the cost-of-living crisis has added<br />

pressure that may also result in a change of behaviour or personal<br />

circumstances.<br />

That’s why we’ve enhanced our existing provision for customers who<br />

may be experiencing a wide range of issues or changes that make<br />

their lives harder. We are now in a position to provide exactly the right<br />

support for their needs through the clinically-led Crawford Customer<br />

Enhancement Service. We have built a dedicated solution rooted<br />

in clinical practices to help the industry identify and assess the risk<br />

category for each customer, ensuring the claims process is adjusted to<br />

help customers feel more comfortable and secure.<br />

Each member of the team has a background in Occupational Health,<br />

Medicine or Social Care (as well as a counselling qualification), all of<br />

which creates the perfect environment for customers to share their<br />

experiences. As a consequence, this allows the most appropriate<br />

adjustments to be made.<br />

Since we introduced the service, we have seen a variety of referrals<br />

to our Customer Enhancement Service team, covering issues such as<br />

bereavement, disability, isolation, complex trauma and PTSD, financial<br />

difficulties, depression, suicidal ideation, and anxiety.<br />

Use of our Individual Assistance Plan (IAP) support has also increased.<br />

Alongside the live support from our Customer Enhancement Advisors,<br />

our IAP provides wrap-around support to customers during and after<br />

their claim. At no extra cost to the client, we can provide customers<br />

with access to a wide range of support services based online, via an<br />

app or telephone, with services available 24 hours a day, 365 days<br />

a year. This also includes access to BACP accredited counsellors,<br />

financial advisors and legal assistance.<br />

Since introducing our new service for specific clients, we have<br />

witnessed a 51% reduction in elapsed settlement times, a 50%<br />

reduction in complaints, an 18% increase in compliments, and a 36%<br />

reduction in indemnity spend. This approach is not only good for the<br />

customer and compliance; it also makes great business sense.<br />

Hannah Gardner,<br />

Customer Enhancement Service Lead, Crawford & Co.<br />

Consumer Duty Regulations<br />

and the World of Vehicle<br />

Recovery<br />

As the Financial Conduct Authority (FCA)<br />

introduce their new Consumer Duty<br />

regulations, insurers are asking many<br />

companies in the claims supply chain about<br />

how they plan to set the higher and clearer<br />

standards of consumer protection required,<br />

and how they intend to put the needs of the<br />

customer first.<br />

It’s probably fair to say that, save for the last few years, roadside<br />

recovery hasn’t been at the top of everyone’s supply chain agenda.<br />

As a result, vehicles would regularly be recovered by the Police or<br />

Highways authorities at substantially inflated charges, and then ‘lost’<br />

or left in storage for some considerable time.<br />

However, the market has moved on, and it’s now widely recognised<br />

that the recovery agent and their driver is, on many occasions, the<br />

only face of the insurer brand that the customer will ever meet in<br />

person. Therefore, it’s hugely important that the experts taking the<br />

initial call have undertaken in depth vulnerability assessments, and<br />

that the attending driver is clear and concise in terms of next steps, as<br />

well as the options open to the customer around onward transport.<br />

At NWVA, these vulnerability assessments are not new. However, we<br />

recognise that it’s no longer as simple as having young children in<br />

the car, or an elderly person on a country road. Vulnerability is much<br />

broader than that, and it’s a key part of what we do when assessing<br />

recovery needs.<br />

Looking after the customer and not just the vehicle is central to our<br />

assessment process, as well as a core part of our drivers’ ongoing<br />

development programme. We recognise that accidents are distressing<br />

enough, and being left with a damaged or undriveable car at the side<br />

of the road only leads to increased stress. Therefore, arrival times and<br />

continual communication with the customer is absolutely paramount.<br />

To find out how we can help your customers, please contact the team<br />

at sales@nwva.co.uk or by calling 01<strong>62</strong>1 730039. You can also visit our<br />

website at: www.nwva.co.uk<br />

Mick Jennings,<br />

Managing Director, Nationwide Vehicle Assistance (NWVA)<br />

MODERN INSURANCE | 25


EDITORIAL BOARD<br />

The new Consumer Duty<br />

at RGI Solutions<br />

In our commitment to Consumer Duty, we take<br />

immense pride in our deep understanding of both<br />

our team members and, most importantly, our<br />

valued customers. We firmly believe that cultivating<br />

an engaging, supportive, and high-performing<br />

work environment for our team empowers them<br />

to deliver excellence to our customers. This<br />

fundamental principle seamlessly aligns with our<br />

comprehensive Sustainability Strategy.<br />

The core of RGI’s ethos has always revolved around demonstrating<br />

how our customers’ needs are at the very heart of everything we do.<br />

To ensure the consistent application of this ethos throughout our<br />

organisation, we have implemented several key initiatives.<br />

Educating Our Teams. We are actively developing comprehensive<br />

communication materials designed to introduce the principles of<br />

Consumer Duty to our teams. These materials not only elucidate our<br />

responsibilities as a business, but also provide insights into how we<br />

meet the stringent requirements set forth by the regulator.<br />

Sharing Success Stories. We believe in leading by example. Therefore,<br />

we regularly share success stories and case studies that showcase<br />

the various ways in which we consistently deliver positive customer<br />

outcomes. These real-life examples serve as a source of inspiration<br />

and guidance for our teams.<br />

Management Focus on Customers. In our monthly management<br />

meetings, we have instituted a dedicated agenda item centred around<br />

the customer. We also plan to extend this focus to target good<br />

customer outcomes, meticulously reviewing customer metrics to<br />

ensure strict compliance with FCA requirements.<br />

Vulnerable Customer Training. Acknowledging the importance<br />

of addressing the unique needs of vulnerable customers, we<br />

have included comprehensive vulnerable customer training as a<br />

fundamental component of our induction training plan for several<br />

years. We are confident that this training remains not only fit<br />

for purpose but also indispensable, and we are committed to its<br />

continued integration.<br />

At RGI Solutions, our unwavering dedication to Consumer Duty<br />

underscores our commitment to delivering superior customer<br />

experiences. Through these proactive measures and initiatives, we aim<br />

to exceed the expectations of our valued customers. As we continue<br />

to evolve and adapt in an ever-changing business landscape, our<br />

steadfast focus on our customers will remain at the forefront of our<br />

operations, driving our pursuit of excellence and trustworthiness.<br />

Sarah Glenn,<br />

Commercial Director, RGI Solutions<br />

Offering Customer Choice and<br />

Providing a Digital Footprint<br />

The parallels between professional footballers<br />

and claims handlers are not immediately<br />

obvious. But push aside the stadium, stardom<br />

and sporty kits, and the similarities rise to the<br />

fore. Role requirements include embracing<br />

teamwork and clear communication,<br />

maintaining focus yet remaining calm under<br />

pressure, and respecting strong leadership<br />

to reach a shared goal. And when the going<br />

gets tough, there’s a simple yet fundamental<br />

philosophy for success.<br />

Controlling the controllables has been the mantra of sports coaches<br />

and insurance leaders for decades, and this has never been more<br />

significant than it is today. After two years of rising inflation,<br />

policyholders are feeling the financial strain, and whilst we can’t<br />

control inflation any more than we can control the Premier League,<br />

we can influence overall claims costs in the policyholder’s favour<br />

whilst streamlining operations to manage our operating expenses.<br />

Proactive intervention and recovery. FMG intervene with over 24,000<br />

at-fault accidents per year, managing the third party’s claim with a<br />

quality vehicle repair and replacement vehicle service to keep our<br />

customer’s total claim cost to a minimum. Our ULR experts step in<br />

when our customer is not at fault, recovering over £1.7m per month in<br />

uninsured losses on their behalf.<br />

Controlling repair costs. We eliminate bodyshop waste, drive<br />

efficiencies in repair processes, and only use high quality (but<br />

competitively priced) paint, tools and equipment, including non-<br />

OE and green parts options. Our in-house independent automotive<br />

engineers verify repair estimates and keep a close eye on repair<br />

progress, ensuring quality repairs at the right price.<br />

Vehicle recovery and storage. We control recovery and storage costs<br />

for our customers following road traffic accidents, quickly recovering<br />

RTA vehicles to their point of destination. Here, our experts efficiently<br />

assess the damage, and triage to pursue total loss, salvage or repair<br />

routes.<br />

Digitalisation and robotics. We’ve invested in digitalisation and<br />

robotics to streamline and automate processes. FMG Connect, our<br />

omni-channel communications platform, gives customers choice in<br />

how they interact with us, controlling operating costs for both clients<br />

and ourselves.<br />

Colleague engagement and retention. Our DE&I, personal<br />

development, employee engagement and wellbeing strategies<br />

support our aim to nurture our company culture. In turn, this<br />

promotes the efficacy of retaining talent, key knowledge and<br />

expertise, which means that we’re able to support customers<br />

consistently whilst averting the high cost of recruiting and retaining<br />

new employees.<br />

We’re not a top flight sports club, and we can’t control the economy.<br />

But we are a responsible, sustainable business, dedicated to focusing<br />

on the areas of our operation that we can control, and excelling at<br />

providing support for our customers through this economic storm.<br />

Andrew Chandler,<br />

Sales Director, FMG<br />

MODERN INSURANCE | 27


INVESTIGATION WITH<br />

REAL INSIGHT<br />

It’s not by chance that RGI Solutions<br />

has grown to become one of the UK’s<br />

leading independent insurance<br />

investigation specialists. When we set<br />

out in business back in 1990, our<br />

mantra was simple: ‘to provide<br />

integrity, reliability, insight, value<br />

and quality in everything we do’.<br />

TAILORED SOLUTIONS<br />

AT YOUR SERVICE<br />

About Us<br />

Today, with leading insurance<br />

companies, solicitors, self-insurers<br />

and claims handling companies<br />

among our clients, our founding<br />

principles remain just as important to<br />

us as they did all those years ago.<br />

Proud of our heritage, clear fixedprice<br />

services and outstanding fraud<br />

savings rate, we deliver exceptional<br />

value.<br />

Believing that being ‘good’ really<br />

isn’t good enough, we view the<br />

service level agreement we establish<br />

with each client as the absolute<br />

minimum standard we must achieve.<br />

0161 486 0100<br />

Our portfolio of services is regularly<br />

reviewed to ensure we provide<br />

comprehensive, up-to-date and<br />

effective investigation solutions. Most<br />

importantly, each service is tailored to<br />

clients’ specific needs and fully<br />

compliant with the jurisdiction in<br />

which we operate.<br />

THE INTELLIGENT CHOICE<br />

With highly experienced, qualified and<br />

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Integrity, reliability, insight, value and quality<br />

Address : The Chambers, 44 Station Road,<br />

Cheadle Hulme, SK8 7AB<br />

Mailbox : sales@rgisolutions.co.uk


ASSOCIATIONS ASSEMBLE<br />

ASSOCIATIONS<br />

ASSEMBLE<br />

Welcome to<br />

Associations Assemble!<br />

<strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong> is delighted to be joined by some of the leading<br />

names from our industry associations, organisations and institutes.<br />

This issue voices the thoughts of:<br />

David Sparkes<br />

Regulation Director<br />

British <strong>Insurance</strong> Brokers’ Association<br />

(BIBA)<br />

Anthony Hughes<br />

Chairman & CEO<br />

Credit Hire Organisation<br />

(CHO)<br />

Mike Keating<br />

CEO<br />

Managing General Agents’ Association<br />

(MGAA)<br />

Sue Brown<br />

Chair<br />

Motor Accident Solicitors Society<br />

(MASS)<br />

Mike Benner<br />

Chief Executive<br />

Association of Personal Injury Lawyers<br />

(APIL)<br />

Jonathan Drake<br />

Member of the<br />

Forum of <strong>Insurance</strong> Lawyers (FOIL)<br />

and Partner at DWF<br />

Thomas Hudd<br />

National Technical Manager<br />

National Body Repair Association<br />

(NBRA)<br />

Dr Matthew Connell<br />

Director, Policy and Public Affairs<br />

Chartered <strong>Insurance</strong> Institute<br />

(CII)<br />

MODERN INSURANCE | 29


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ASSOCIATIONS ASSEMBLE<br />

David Sparkes<br />

Title: Regulation Director<br />

Association: British <strong>Insurance</strong> Brokers’<br />

Association (BIBA)<br />

Using the Consumer<br />

Duty to Deliver<br />

Good Outcomes<br />

With the Consumer Duty now a key part<br />

of the fabric for all Financial Conduct<br />

Authority (FCA) regulated markets, there<br />

is an expectation that good outcomes will<br />

be the norm for customers as part of the<br />

general service provided - let alone the<br />

claims service.<br />

However, is this truly the case? How many issues will we<br />

see like the one we saw around business interruption<br />

claims, or the accusation that at least one firm was<br />

offering customers less than market value for their cars<br />

in total loss claims?<br />

In reality, there’s an important balance to be made<br />

between customer outcomes and maintaining a<br />

financially stable business. When you set it down in<br />

black and white, it becomes rather obvious that it’s<br />

not possible to sustain ‘competition in the interests<br />

of customers’ (to use the terminology in the relevant<br />

FCA objective) if a firm’s claims payments exceed their<br />

premium income and any reserves.<br />

So, how does a firm strike the right balance?<br />

Communications play a vital role, both in terms of<br />

what teams within firms hear about the service and<br />

outcomes they are employed to deliver, and the<br />

messages that customers hear or read as part of the<br />

arrangement or claims process. The ‘old’ standard of<br />

‘clear, fair, and not misleading’ is now the baseline, not<br />

the expected standard.<br />

A key part of the Consumer Duty requires a guarantee<br />

of customer understanding when it comes to what<br />

they have been told. This needs to be a detailed<br />

conversation, but not a technical one, otherwise<br />

customer understanding will go out of the window.<br />

Customers that understand their claims settlement<br />

and accept this as meeting the expectations of their<br />

insurance cover will result in good outcomes.<br />

Mike Keating<br />

Title: CEO<br />

Association: Managing General Agents’<br />

Association (MGAA)<br />

MGAs: Vital Support<br />

for Brokers<br />

The relationship between brokers and<br />

MGAs has gone from strength to strength<br />

in recent years. Looking at our membership<br />

figures alone, 90% of MGAA members<br />

now distribute products via the broker<br />

community, a figure that continues to grow.<br />

Where MGAs were once seen by the insurance industry<br />

as niche outsiders, they are quickly becoming the go-to<br />

way for brokers to place business on behalf of their<br />

clients. But why is this the case?<br />

Perhaps one of the more obvious reasons is that MGAs<br />

cover risks in niche markets, and many larger insurers<br />

don’t have the resource, appetite or expertise to<br />

compete. But this is just the tip of the iceberg in terms<br />

of the value that MGAs can offer.<br />

Because of the agile nature of MGAs, they’re able to<br />

provide a level of service which larger organisations<br />

would naturally struggle to achieve. From a broker<br />

panel session at our recent annual conference, we know<br />

that an MGA’s tailored, efficient, and personal approach<br />

to customer service is one of the key benefits of their<br />

offering.<br />

We also know that brokers appreciate having greater<br />

access to decision-makers within the businesses they<br />

partner with, which further adds to the overall positive<br />

experience of working with MGAs.<br />

MGAs have been fundamental in helping brokers tackle<br />

the economic headwinds that the industry continues<br />

to battle against. As insurance prices continue to<br />

rise, MGAs have been able to offer tailored solutions<br />

centered around the needs of the broker and their<br />

clients, a proposition which is difficult to find elsewhere.<br />

The fact that relationships<br />

between MGAs and their<br />

broker partners continue to<br />

thrive is a testament to the<br />

value they provide - not only<br />

to brokers themselves, but<br />

to the industry as a whole.<br />

MODERN INSURANCE | 31


ASSOCIATIONS ASSEMBLE<br />

Mike Benner<br />

Title: Chief Executive<br />

Association: Association of Personal Injury<br />

Lawyers (APIL)<br />

The Justice Gap<br />

Many people injured in road collisions<br />

are not receiving compensation since the<br />

‘whiplash reforms’, where damages were<br />

slashed and the Official Injury Claim (OIC)<br />

system was introduced.<br />

A clear ‘justice gap’ has been unveiled by APIL’s<br />

dedicated research team, which tracks and analyses<br />

data relating to justice for victims of negligence. Data<br />

is studied from a broad range of sources and addresses<br />

a variety of issues - from criminal injury claims to birth<br />

rates, insurance premiums, traffic concentrations, court<br />

delays, and in this case, access to justice and injury<br />

levels.<br />

The team has unearthed some stark results. Comparing<br />

the landscape today to how it looked pre-pandemic,<br />

the number of people injured in road traffic collisions<br />

has increased by 18%, while the number of people<br />

claiming compensation is down by a quarter. Far more<br />

people are being injured, yet there are fewer claims. The<br />

only explanation lies with the reforms.<br />

The Government believed the insurance industry when<br />

it said that the cost of compensating people for injuries<br />

made premiums high, and that premiums would go<br />

down if the reforms were introduced. However, APIL<br />

analysis shows that insurance premiums are creeping<br />

ever higher – 41% higher than in 2021, in fact, according<br />

to data from the Office of National Statistics. The<br />

situation is wholly unfair, and smacks of poor policy.<br />

Injured victims of negligence were never the problem.<br />

We hope that insurers will be held to account when<br />

the Treasury reports on the benefits of the reforms to<br />

consumers. The damage is already done for the many<br />

road crash victims who will never get the compensation<br />

they need to help get their lives back on track. The law<br />

is there to provide for the needs of injured people. It is<br />

the Government’s job to make sure it does exactly that<br />

in the future.<br />

Anthony Hughes<br />

Title: Chairman & CEO<br />

Association: Credit Hire Organisation (CHO)<br />

Consumer Duty:<br />

Overly Onerous, or<br />

a Necessary Check<br />

on Overzealous<br />

Capitalism?<br />

Preparing for the Consumer Duty has<br />

been a massive exercise for the insurance<br />

industry. One major player sent 14,000<br />

emails and other such material to their<br />

broking partners over a five-month period,<br />

to help them understand what the new<br />

regulations required.<br />

According to the Financial Conduct Authority (FCA),<br />

the new Consumer Duty sets higher and clearer<br />

standards of consumer protection across financial<br />

services, and requires firms to put their customers’<br />

needs first. This is especially important in light of the<br />

cost-of-living crisis and the number of customers<br />

showing vulnerability characteristics. The FCA<br />

estimates that 47% of the adult population exhibits one<br />

or more of these traits.<br />

But how easy is it for insurers to put customers first,<br />

when they have a competing fiduciary duty to their<br />

shareholders? In the last 18 months, car insurance<br />

premiums have rocketed thanks to surging claims<br />

inflation. Customers, even those with a zero claims<br />

history, have been hit by 40%+ price hikes, which<br />

insurers say is needed to fill the hole in their balance<br />

sheets.<br />

We see similar issues across many other regulated<br />

industry sectors. Water companies are under fire<br />

for paying out dividends instead of investing in<br />

infrastructure to stop our rivers filling up with sewage.<br />

Energy companies have been accused of profiteering<br />

from the energy crisis; Centrica reported record profits<br />

of £3.3bn back in February.<br />

To add to the consumer/shareholder paradox, there<br />

are calls, mostly from the political right, for regulatory<br />

burdens to be further relaxed,<br />

especially where issues<br />

such as ESG and EDI are<br />

concerned - both of which<br />

are allegedly stifling<br />

corporate growth.<br />

No one piece of<br />

regulation is perfect, but<br />

if the FCA feels the need<br />

to demand more of big<br />

business, the complex<br />

balance of interests<br />

between consumers and<br />

shareholders may come<br />

to be out of kilter.<br />

MODERN INSURANCE | 33


ASSOCIATIONS ASSEMBLE<br />

Sue Brown<br />

Title: Chair<br />

Association: Motor Accident Solicitors Society<br />

(MASS)<br />

2024: A Year for<br />

Statutory Review<br />

2024 is an important year for the sector.<br />

The general election could confirm a<br />

continuation of digitisation policy and<br />

continued cost suppression across even<br />

more areas of civil law. On the other hand,<br />

there could be a Labour government,<br />

resulting in a different tone and set of<br />

policies altogether.<br />

Next year will also herald a statutory review of many<br />

aspects of the Civil Liability Act 2018. The recent<br />

Justice Committee report on the OIC portal set<br />

out some of the obvious problems in stark terms -<br />

highlighting a growing number of unresolved claims<br />

and claims that are taking longer to reach settlement,<br />

continued technical issues for professional users, and<br />

less than 10% of OIC users representing themselves - all<br />

despite a dramatic fall in the number of claims.<br />

These issues are not just operational, but policy driven.<br />

They are the result of a badly conceived system, built<br />

and developed for less than 10% of users. Many law<br />

firms have exited the market, while others are still trying<br />

to make the economics work at the low-value level.<br />

Ten years of fixed costs without an uplift are inevitably<br />

taking its toll.<br />

Insurers may have legitimate concerns around fraud.<br />

However, in a deliberately light-touch regulatory<br />

system, already lacking the most basic checks, fewer<br />

lawyers will mean even fewer checks for fraud. We need<br />

to work together to address these concerns, rather<br />

than looking to relocate the boundaries yet again.<br />

Hopefully, some of these issues will be confronted next<br />

year in the statutory review. The tariff of damages will<br />

be reconsidered. The definition of whiplash may be<br />

revisited. For insurers, the Financial Conduct Authority<br />

and the Treasury will determine whether the savings<br />

from the reforms have been passed on to consumers<br />

through a reduction in their motor premiums.<br />

Parliament will delve deeper into the OIC. We should<br />

all hope that what<br />

emerges is a better,<br />

more efficient and<br />

fairer process.<br />

Jonathan Drake<br />

Title: Member and Partner<br />

Association: Forum of <strong>Insurance</strong> Lawyers (FOIL)<br />

and DWF<br />

Consumer Duty &<br />

Claims<br />

We are now a couple of months into the<br />

new era of Consumer Duty requirements<br />

for authorised firms in the insurance<br />

sector. Although this is inevitably a very<br />

early point in its journey, we can already<br />

discern some emerging themes and areas<br />

of concern from the regulator, especially in<br />

relation to claims and claims handling.<br />

We know from a recent exchange of correspondence<br />

between the Financial Conduct Authority (FCA) and<br />

the House of Commons Treasury Select Committee<br />

that in relation to claims handling by small and medium<br />

insurers (including all authorised firms involved in those<br />

processes), the FCA is:<br />

• Engaging with firms, including small and medium size<br />

firms, to understand their settlement processes and<br />

their internal procedures for ensuring consistency in<br />

quality across all claims - irrespective of whether it is<br />

outsourced - in order to prevent customers from being<br />

at a disadvantage;<br />

• Monitoring claim handling processes and outcomes.<br />

For example, the FCA worked with Direct Line Group<br />

back in June to carry out an extensive review of<br />

their claim settlements between September 2017<br />

and August 2022, identifying and redressing any<br />

policyholders who had received unfair settlements;<br />

• Analysing data provided from the Financial<br />

Ombudsman Service and engaging in discussions<br />

surrounding emerging issues and trends. As a result<br />

of this work, the FCA have identified specific issues<br />

relating to motor total loss claims, where cars were<br />

judged total write offs.<br />

It is clear, therefore, that even though we are only a<br />

couple of months into the new Consumer Duty era, the<br />

FCA is paying particular attention to the outcome of<br />

claims for consumer policyholders. There is no reason to<br />

believe that this level of scrutiny<br />

will cease any time soon.<br />

MODERN INSURANCE | 35


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ASSOCIATIONS ASSEMBLE<br />

Thomas Hudd<br />

Title: National Technical Manager<br />

Association: National Body Repair Association<br />

(NBRA)<br />

Consumer<br />

Protection in<br />

the Automotive<br />

Repair Industry<br />

The National Body Repair Association<br />

(NBRA) recognises the evolving regulatory<br />

landscape and the challenges it presents<br />

- particularly for repairers who, while not<br />

directly regulated, collaborate with insurers<br />

as approved repairers.<br />

We acknowledge that adhering to Financial Conduct<br />

Authority (FCA) requirements can burden repairers<br />

who may not fall under direct regulation. Nevertheless,<br />

embracing compliance as a fundamental aspect<br />

of working with insurers is essential for approved<br />

repairers. Moreover, compliance should be reflected in<br />

the compensation methods for repair services.<br />

Every repairer that becomes a member of the NBRA is<br />

inspected to ensure that they are operating legally and<br />

legitimately, with the correct facilities and capabilities<br />

to competently repair vehicles following an accident.<br />

All new members also join our Chartered Trading<br />

Standards Institute (CTSI) approved Code of Practice,<br />

which offers additional protection to customers in the<br />

event of issues following a repair.<br />

The NBRA are audited annually by the CTSI to ensure<br />

our compliance in upholding the principles of the Code<br />

of Practice. A key measure from the Code of Practice<br />

involves monitoring customer satisfaction, which must<br />

be recorded by a NBRA Code of Practice approved<br />

repairer. Our most recent annual report covering March<br />

2022 to Feb 2023 shows that 15,900 reviews were<br />

audited, and an overall score of 4.6 out of 5 was given.<br />

In conclusion, while we acknowledge the compliance<br />

burden that FCA requirements place on repairers -<br />

especially those that are not directly regulated - we<br />

emphasise the importance of aligning with insurers for<br />

approved repairers. Compliance should be considered<br />

an integral part of this collaboration and reflected in<br />

compensation methods. A cooperative approach that<br />

recognises the mutual benefits of compliance can lead<br />

to fair compensation, increased transparency, and a<br />

better consumer experience. With our Code of Conduct<br />

and arbitration services, we<br />

can uphold the principles<br />

of professionalism and<br />

consumer protection in the<br />

automotive repair industry.<br />

Dr Matthew Connell<br />

Title: Director, Policy and Public Affairs<br />

Association: Chartered <strong>Insurance</strong> Institute<br />

(CII)<br />

Is the insurance<br />

sector ready for the<br />

Consumer Duty?<br />

In September, the Financial Conduct<br />

Authority (FCA) published a ‘Dear CEO’<br />

letter for insurers that covered a wide<br />

range of outstanding issues, including<br />

speed of claims, treatment of existing<br />

customers, and vulnerability.<br />

Our tracking of public opinion over the last four years<br />

has told us that consumers also take these issues<br />

seriously.<br />

Much of our research shows that insurers and<br />

brokers are performing solidly against key indicators,<br />

such as treating customers with respect during the<br />

claims process, communication, price, and quality of<br />

product. There is room for improvement in all of these<br />

categories, but most customers are satisfied with the<br />

service they are getting.<br />

However, consumers still don’t believe that they<br />

are getting a fair deal on loyalty, despite FCA rules<br />

introduced last year designed to ensure that new and<br />

existing customers are given equal treatment.<br />

So, what do insurers need to do to make sure they are<br />

delivering the right outcomes for the overwhelming<br />

majority of consumers?<br />

Our research findings show three key themes:<br />

• The cost-of-living crisis has created much higher<br />

expectations around speed of claims. Insurers<br />

have largely risen to the challenge, gaining higher<br />

performance ratings from most customers. However,<br />

any slip in performance means that customers are<br />

more likely to complain.<br />

• Existing customers want to see solid evidence that<br />

they are being treated in the same way as new<br />

customers. This could take the form of genuine<br />

rewards for loyalty.<br />

• Consumers want to be treated as individuals when<br />

it comes to assessing risk, complaints and flexibility<br />

around claims and cover.<br />

Getting these three<br />

elements right will boost<br />

insurers’ performance<br />

against the Consumer<br />

Duty from a solid pass<br />

to a stellar grade, making<br />

the next ‘Dear CEO’ letter<br />

a much more comfortable<br />

read.<br />

MODERN INSURANCE | 37


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FEATURES<br />

Just a<br />

Thought<br />

from Eddie Longworth<br />

Suppliers<br />

Must Also<br />

Deliver<br />

Consumer<br />

Duty<br />

Obligations<br />

At a recent meeting<br />

of around 50 different<br />

representatives within<br />

the claims supply chain -<br />

spanning repair, IT, legal,<br />

and other sub-sectors -<br />

there was an interesting<br />

discussion around the<br />

new Consumer Duty<br />

rules. The meeting had<br />

a collective sigh of relief<br />

from suppliers, who are<br />

not directly part of the<br />

regime.<br />

We know that insurers have a whole new<br />

host of things to think about, plan for,<br />

and implement. But the perception that<br />

suppliers have escaped the ‘burden’ of<br />

these new regulations is simply incorrect.<br />

Any supplier’s key role is to help meet the<br />

needs and desires of their clients (at a profit<br />

to themselves), and so logic dictates that if<br />

a client has Consumer Duty obligations to<br />

meet, then the supplier must also be a part<br />

of that solution. Nor am I referring just to<br />

those suppliers that may have some formal<br />

delegation of claims management authority.<br />

Every supplier of any element of the<br />

claims journey must understand these new<br />

requirements fully, and leap to offer new<br />

solutions that will help their clients.<br />

Gaining Competitive Advantage<br />

Surely those suppliers that are first in the<br />

queue to offer their support and services<br />

will be looked upon most favourably when<br />

the next batch of tender documents arrive?<br />

The question around ‘added value’ that a<br />

supplier could proffer as part of the tender<br />

response is invariably filled with corporate<br />

waffle or, even worse, financial inducements<br />

that have never been asked for.<br />

Instead, it would be a refreshing change<br />

for a supplier to position themselves as a<br />

firm with a genuine understanding of the<br />

new needs of their clients, and respond<br />

accordingly - not that you should wait<br />

until the next tender comes along to gain<br />

advantage! I wonder how many suppliers<br />

have proactively started a conversation<br />

with their Supply Chain Manager or Claims<br />

Director in order to throw their hat into the<br />

ring as being part of potential Consumer<br />

Duty solutions…<br />

Proactive Support Wins the Day<br />

In a great many instances, it is the<br />

supplier that has direct interface with the<br />

policyholder, and will be the ‘face’ of the<br />

claims department. But even where this is<br />

not the case (IT companies, for example),<br />

there is still a continuous obligation on<br />

suppliers to build system, process, and<br />

people skills/knowledge around helping the<br />

insurer to work within the new regime.<br />

Of course, I am aware that suppliers already<br />

provide a great many supportive services<br />

above and beyond their core products. But<br />

that is the name of the game. Tesco does<br />

not supply ‘free’ parking in addition to their<br />

core food and associated products because<br />

they really want to – it’s because that is<br />

a support service that their customers<br />

demand and expect. It’s part of the total<br />

package.<br />

The same goes for suppliers who expect<br />

to win business from the insurer and<br />

claims management communities. If your<br />

clients have a need to fulfil Consumer Duty<br />

regulations, then it is the responsibility of<br />

suppliers to be at the forefront of providing<br />

some of the answers.<br />

Fortune Favours the Brave<br />

Of course, it may cost money. It will<br />

certainly take up management time. There<br />

will be a need to change operational<br />

processes, and perhaps new IT solutions<br />

will be required as well.<br />

But if that is what’s needed – and you want<br />

to stay or become a premier supplier to<br />

your clients – then you need to make a<br />

start right now. The new regime is still in its<br />

early days, and this provides a tremendous<br />

opportunity for suppliers with foresight and<br />

commitment to get in at the ground level,<br />

embedding<br />

themselves<br />

into any new<br />

elements that<br />

the claims<br />

department<br />

needs in order<br />

to comply<br />

with their<br />

Consumer Duty<br />

obligations.<br />

Get on with it!<br />

Eddie Longworth,<br />

Director, JEL Consulting<br />

MODERN INSURANCE | 39


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FEATURES<br />

CONSUMER INTELLIGENCE<br />

October/November 2023 <strong>Issue</strong> No <strong>62</strong><br />

Avoiding<br />

Consumer<br />

Harm in the<br />

Consumer<br />

Duty Age<br />

When the FCA first<br />

proposed the new<br />

Consumer Duty back<br />

in July 2021, little<br />

did we know that<br />

the UK would soon<br />

be hit by a cost-ofliving<br />

crisis. When<br />

the implementation<br />

finally arrived two<br />

years later, the need<br />

for strengthened<br />

consumer protection<br />

couldn’t have felt<br />

more palpable; 69% of<br />

consumers reported<br />

that they had been<br />

impacted by the crisis,<br />

and 66% said that they<br />

are worried about<br />

being unable to afford<br />

their bills.<br />

Record-breaking premium<br />

inflation, delays in pay outs, and<br />

increased fraud activity are driving a<br />

breakdown in trust between insurers<br />

and consumers. The industry is<br />

standing on a precipice; one where<br />

it needs to embrace the spirit of the<br />

Consumer Duty in order to survive.<br />

Unfortunately, Ian Hughes, CEO<br />

at Consumer Intelligence, says the<br />

reception from the market has been<br />

mixed. “Some firms have jumped<br />

on it,” Ian says, “while others really<br />

haven’t understood it. Given the<br />

amount of signposting, it does seem<br />

surprising that there has been so<br />

much ‘nothing to see here’ from so<br />

many companies”.<br />

Ian continues, “I expect to see the<br />

impact of this mentality pan out in<br />

the market – whether insurers are<br />

asked to review historic claims or<br />

asked to review their fee structure.<br />

All of these are sign posts for what<br />

the Consumer Duty means”.<br />

Intensifying consumer<br />

expectations<br />

The world we once knew, one<br />

where savvy customers shopped<br />

around for new business discounts,<br />

is starting to seem like a distant<br />

memory. Today’s customer doesn’t<br />

have that luxury. In reality, they’re<br />

facing significant increases in<br />

renewal premium, with little relief<br />

offered from shopping around.<br />

Consumer Intelligence data shows<br />

new business insurance premiums<br />

inflating by 61% in motor and 27%<br />

in home in the twelve months to<br />

August.<br />

Alongside increased costs<br />

comes an increase in consumer<br />

expectations. Hughes says, “If you<br />

were suddenly asked to pay 50%<br />

more for your favourite dish at<br />

your local restaurant, you’d expect<br />

an improvement in quality or<br />

service. The same applies to any<br />

consumable, including insurance”.<br />

“Our research shows that consumer<br />

expectations are currently not being<br />

met consistently - particularly<br />

during the claims process when<br />

it comes to speed and efficiency.<br />

If delays in pay outs continue,<br />

consumer satisfaction will<br />

continue to fall, leading to further<br />

complaints and potential regulatory<br />

consequences”.<br />

The potential for<br />

consumer harm<br />

With costs rising on all sides, more<br />

customers are shopping around<br />

at renewal, making them more<br />

susceptible to unfair practices which<br />

artificially lower premiums.<br />

Customer understanding of general<br />

insurance products is lower than<br />

many firms may realise, and lower<br />

still as a result of the proliferation<br />

of tiered products – those which<br />

typically strip out cover and raise<br />

excesses.<br />

In a survey of 1056 people conducted<br />

in February, Consumer Intelligence<br />

found that knowledge about cover<br />

levels and excess fees varied widely.<br />

More than 1 in 5 of those with<br />

insurance had no idea what level<br />

of motor (22%) or home (21%) cover<br />

they’d purchased – top, standard,<br />

or basic.<br />

When asked in more detail about<br />

the level of cover they had, as many<br />

as 46% of car insurance customers<br />

had no idea how much excess they’d<br />

agreed to pay in the event of a<br />

claim, rising to nearly 60% of home<br />

customers.<br />

Hughes comments, “We’ve seen<br />

an explosion of product tiers<br />

following the General <strong>Insurance</strong><br />

Pricing Practices (GIPP) reforms,<br />

with brands bringing out bronze/<br />

silver/gold versions to serve different<br />

consumer budgets, and to gain an<br />

advantage on the Price Comparison<br />

Websites”.<br />

“The FCA has been about as clear<br />

as it can be on the subject of Fair<br />

Value. They have also been clear<br />

about what they are planning<br />

with anti-avoidance. Having tiered<br />

products is not necessarily a<br />

problem, however it does become<br />

one when tiers result in individual<br />

products within a package failing<br />

to offer fair value, or where tiered<br />

products are being used as a way to<br />

avoid Consumer Duty principles,<br />

achieving pricing outcomes to the<br />

detriment of consumers.”<br />

“The biggest worry has to be if<br />

consumers are lured into buying<br />

sub-standard products out of<br />

necessity, which means that they<br />

end up not having the right cover.<br />

This will cause reputational<br />

damage for the industry and<br />

could lead to long term harm and<br />

vulnerability for consumers.”<br />

Time to understand<br />

your performance<br />

Considering current challenges,<br />

trends and practices, it is essential<br />

that firms fully embrace the spirit<br />

of the new regulation to avoid the<br />

potential for consumer harm that<br />

currently exists.<br />

For those firms with their blinkers<br />

still firmly on, convinced they<br />

have everything in order, Hughes<br />

encourages them to assess their<br />

performance in the context of the<br />

market.<br />

“Too many firms lack insight on<br />

their market position and would<br />

benefit from a clear, unbiased<br />

view on how they measure up,<br />

helping them avoid the perils of<br />

marking their own homework.<br />

Understanding performance<br />

in the context of the wider<br />

market will help companies test<br />

internal assumptions, prioritise<br />

areas for improvement, boost<br />

competitiveness, and demonstrate<br />

their commitment to delivering<br />

high standards for customers to the<br />

FCA.”<br />

MODERN INSURANCE | 41


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MEET THE JUDGES<br />

CHAIR<br />

David J Williams - Chair of the Fire Protection Association (FPA),<br />

Former MD of Claims & Underwriting at AXA <strong>Insurance</strong><br />

VICE CHAIR<br />

Suneeta Padda - Director, Padda Consulting<br />

Michael Keating - CEO, Managing General Agents’ Association (MGAA)<br />

Susan Brown - Director and Chair, Motor Accident Solicitors Society (MASS)<br />

Anthony Hughes - Chairman & CEO, The Credit Hire Organisation (CHO)<br />

Ursula Jallow - Director, <strong>Insurance</strong> Fraud Bureau (IFB)<br />

Kirsten Mitchell-Wallace - Director of Portfolio Risk Management,<br />

Lloyds of London<br />

John McQuater - President, Associations of Personal Injury Lawyers (APIL),<br />

Director & Joint Head of Personal Injury at Switalskis Solicitors<br />

Julia Graham - CEO, AIRMIC<br />

Sue McCall ACII - Chartered Insurer, Past Chair of Society of Claims<br />

Professionals & Panel Member of the CII General <strong>Insurance</strong> Learning<br />

Advisory Panel, Senior Manager - Claims Management at MS Amlin<br />

Underwriting Limited<br />

Huw Evans - Partner, <strong>Insurance</strong>, KPMG in the UK<br />

Donna Scully - Joint Owner/Director, Carpenters Group<br />

Laurence Besemer FCII - CEO, Forum of <strong>Insurance</strong> Lawyers (FOIL)<br />

Denise Garth - Chief Strategy Officer, Majesco<br />

Rory Pyke - Global Partnerships Manager, Insurtech Insights<br />

Helena Evans - Head of Specialist Services at Criterion and Immediate<br />

Past President of the Chartered Institute of Loss Adjusters (CILA)<br />

Chris Payne - EMEIA <strong>Insurance</strong> Technology Leader, (EY)<br />

Rory Yates - CSO, EIS Ltd<br />

Dr Renu Ann Joseph - Founder & CEO, Luminant Analytics<br />

Eddie Longworth - Director, JEL Management Consultancy Ltd<br />

Sabine VanderLinden - CoFounder & Managing Partner, Alchemy Crew<br />

Claire McDonald - Member of the Board – HDI Global SE, Chair of iWIN<br />

<strong>Insurance</strong> Women Inclusivity Network<br />

John Thompson - Chairman, British Damage Management Association (BDMA)<br />

Matthew Maxwell Scott - Executive Director, The Association of Consumer<br />

Support Organisations (ACSO)


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FEATURES<br />

Meet the Company:<br />

Internal Satisfaction Informs Customer Satisfaction<br />

With staff satisfaction at an all-time high, EDAM have strengthened their internal culture<br />

in order to guarantee a top level of service and support for their customers.<br />

Post-accident management company EDAM have spent the last<br />

two years reshaping and transforming their business to provide<br />

a strong culture and platform for continued growth. With<br />

employee retention and engagement at an all-time high, the<br />

positive impact on growth and customer satisfaction has never<br />

been higher.<br />

Simon Gallimore, Chief Executive Officer, said, “We’ve really<br />

committed to improving our internal culture and creating a<br />

professional environment with a true family feel. When you<br />

give the best to your team, you receive the best for your<br />

customers. That’s never been more evident within our business.<br />

We are dedicated to maintaining a healthy internal culture, but<br />

now that we have laid the foundations, we can really define<br />

our company’s mission and enhance our proposition for our<br />

customers”.<br />

EDAM undertook a leadership feedback evaluation, inclusive of<br />

a trusted leader review. This review saw 92% of the EDAM team<br />

respond to say that they ‘trust their line manager’. It also found<br />

that over 90% of EDAM staff consider their leadership to be role<br />

models of EDAM’s values, and 93% felt their leader always acts<br />

with integrity.<br />

Simon continued, “This leadership feedback review<br />

demonstrates that our dedication has paid off. These are the<br />

highest scores I have known in my professional career – a real<br />

endorsement of our ‘people first’ approach. We’ve fostered a<br />

great culture of trust with our people, which is centred around<br />

the basic leadership principles of integrity, benevolence and<br />

ability. Overlaying this with our company values, which were<br />

created by our staff, we have created a truly winning culture”.<br />

EDAM’s dedication to their team goes deeper than leadership<br />

reviews. When Simon joined the business, he made a<br />

commitment to promote from within and has harnessed a<br />

‘grow your own’ strategy where internal talent is nurtured and<br />

recognised. Using the company’s ‘Learning Hub’ and leadership<br />

development programme, every employee has a clear career<br />

ladder that they can choose to follow. Internal movement<br />

across departments has never been higher, which allows us to<br />

retain knowledge within the business. There has only been one<br />

external leadership appointment into the business over the past<br />

two years, which is testament to the power of unlocking talent<br />

from within.<br />

Rebecca Chappell, Head of Human Resources, said, “The health<br />

and wellbeing of our staff is a priority. We are always looking at<br />

innovative ways to support our employees, such as ‘wellbeing<br />

days’ which allow time out of work to focus on personal<br />

wellbeing. We also encourage financial education sessions,<br />

which provide one-on-one access to a financial advisor, and<br />

volunteering days, which allow staff the opportunity to give<br />

back to their local community”.<br />

EDAM have recently restructured their team in order to<br />

provide a more customer centric approach to communications.<br />

Customers can now benefit from dedicated teams that<br />

will provide an end-to-end claims experience. In July 2023,<br />

the automotive sector began navigating Consumer Duty<br />

regulations, with EDAM’s new structure and engaged workforce<br />

playing a small part in their commitment to improving<br />

consumer relations.<br />

Their focus on internal satisfaction has seen the company’s<br />

Net Promoter Scores rise to a consistent 80% and above,<br />

demonstrating the stellar service that EDAM provide at every<br />

stage of the client’s journey. From research undertaken by<br />

EDAM to date, both from customers and the wider market,<br />

these internal changes have only served to enhance EDAM’s<br />

service proposition and growing reputation.<br />

About EDAM<br />

EDAM are a market leading accident management<br />

company providing end-to-end claims management<br />

for insurers, brokers, MGA’s and TPA’s. For over<br />

20 years, EDAM have built a reputation of trust,<br />

providing seamless partnerships and a connected<br />

community to support every aspect of the postaccident<br />

journey.<br />

EDAM have an owned fleet providing standard,<br />

prestige and commercial vehicles to customers,<br />

and a nationwide repair network that allows them<br />

to provide mobility and repair solutions.<br />

Everyone at EDAM shares the same collective<br />

passion for service excellence. They continuously<br />

grow together, improving systems, services<br />

and process to deliver best in class accident<br />

management services, providing certainty during<br />

uncertain times.<br />

MODERN INSURANCE | 45


FEATURES<br />

Dive In’s<br />

‘Below the Surface’<br />

Event Shines a<br />

Light on <strong>Insurance</strong><br />

Industry’s Diversity<br />

and Inclusion<br />

Challenges<br />

At Markel’s offices in the heart of<br />

Fenchurch, Dive In, one of the world’s<br />

largest diversity, equity, and inclusion<br />

festivals, hosted an event called<br />

‘Below the Surface - The Unspoken<br />

Side of <strong>Insurance</strong>’. It brought to<br />

light the hidden diversity, equity and<br />

inclusion complexities within the<br />

insurance industry.<br />

The event, presented by The Communication Practice, a drama-based training<br />

company with a focus on fostering diversity, equity, inclusion, and a sense<br />

of belonging (DEIB) within the workplace, was far from your typical industry<br />

event. It took the form of a dynamic workshop, drawing insights from research<br />

conducted across the Lloyd’s Partner Networks.<br />

The research findings were revealing, with 24% of survey respondents feeling<br />

that they couldn’t be their authentic selves at work, and 22% sensing that their<br />

true voices went unheard. With these statistics as a backdrop, the event aimed<br />

to:<br />

• Uncover diverse perspectives and experiences of marginalised individuals in<br />

the insurance field.<br />

• Shed light on perceived barriers and challenges that hinder professional<br />

growth.<br />

• Encourage attendees to take personal actions to challenge workplace biases<br />

and become advocates for others.<br />

One impactful segment featured actors delivering statements derived from<br />

Dive In’s research, underscoring issues such as the industry’s perception as oldfashioned,<br />

and the struggles of those who don’t conform to established norms.<br />

Attendees engaged in a thought-provoking theatrical performance simulating<br />

a one-on-one meeting between a boss, ‘Gary,’ and a junior team member,<br />

‘Richard,’ struggling with ineffective communication. The audience actively<br />

discussed ways in which Gary could have improved the situation, emphasising<br />

the importance of active listening, body language, and making Richard feel<br />

valued.<br />

In breakout sessions, attendees tackled real-life case studies involving actors<br />

facing industry difficulties, including a female executive feeling undermined<br />

by male colleagues and a Muslim mother dealing with workplace inclusivity<br />

challenges due to differences in social activities. Attendees grappled with finding<br />

solutions and acknowledged the need for broader cultural change.<br />

Attendees were also encouraged to reflect on their ‘lightbulb moments’ and<br />

commit to immediate changes in their approach to inclusivity. Organisers<br />

encouraged attendees to introspect and asked critical questions such as:<br />

• Are you genuinely an active ally?<br />

• Do you challenge bad behaviour and recruitment decisions based on ‘gut<br />

instinct’?<br />

• Are you investing in your own development to confront biases?<br />

• How are you contributing to diverse hiring?<br />

• Who are you personally sponsoring and pushing forward within your<br />

organisation?<br />

• Do you regularly review diversity statistics for your team or organisation?<br />

• Are you objective when considering the skills and capabilities of team<br />

members for promotions or new projects?<br />

• Have you provided training to make the workplace more inclusive?<br />

Organisers also shared inclusive communication tips, advocating:<br />

• The need to embrace mistakes as learning opportunities.<br />

• ‘Be the change;’ step outside of your comfort zone.<br />

• That diversity, equity, and inclusion (DEI) isn’t solely HR’s responsibility! Be<br />

prepared to lead from the front.<br />

In his closing remarks, Bruce Carnegie Brown, Chairman of Lloyd’s of London,<br />

commended the presenters for their practical approach to diversity and<br />

inclusion.<br />

He emphasised that inclusion should not be academic but practical and<br />

actionable, urging attendees to spread the message beyond the event’s<br />

confines.<br />

The event illuminated the often-overlooked aspects of the insurance sector.<br />

It provided a platform for open dialogue, learning, and reflection on creating<br />

a more inclusive industry, exemplifying the spirit of Dive In and the ongoing<br />

commitment to diversity, equity and inclusion within the insurance industry.<br />

This event was sponsored by Dive In Global Festival Partners: BMS, Lloyd’s,<br />

Markel, Tokio Marine Kiln, and MS Amlin.<br />

46 | MODERN INSURANCE


FEATURES<br />

5<br />

ARTICLE<br />

Consumer<br />

Duty: An<br />

Illusion??<br />

It seems not a year goes by without a new regulatory or environmental change that becomes the<br />

main industry topic of discussion. In the last five years, we’ve seen fallout from GDPR (2018), Brexit<br />

(2019), COVID-19 (2020), Climate Change (2021), and Claims Inflation (2022). More rules and<br />

regulations add yet more red tape to an already broken system.<br />

In 2023, it’s the turn of ‘Consumer Duty’. What sounds like a<br />

step in the right direction (to improve customer protection<br />

and create better outcomes) has all the qualities of regulatory<br />

bluewashing, where a deceptive slogan overstates an industry’s<br />

commitment to responsible social practice, offering the illusion<br />

that we’re creating better consumer outcomes when we’re<br />

merely tinkering at the edges.<br />

Let’s take the example of home insurance. From a customer<br />

perspective, a good outcome would be for me to know that<br />

costs will be covered when my fence blows over in the wind, or<br />

when my roof tiles fall off. 70% of such claims are automatically<br />

denied, which makes a mockery of insurers telling us that 97%<br />

of claims are paid. ‘Ah, only ‘valid’ claims,’ you retort. Silly me, I<br />

should’ve known better.<br />

Similarly, let’s consider motor insurance. From a customer<br />

perspective, a good outcome would be for me to know that<br />

I‘m not on my own when accidents happen, obliged to sort it<br />

out at my own expense. I’d also want a simple way of covering<br />

the claims excess that I’d previously maxxed in order to obtain<br />

the cheapest quote (this is particularly relevant to vulnerable<br />

customers in short- or long-term financial difficulties who are<br />

most at risk of doing exactly that).<br />

Under the new Consumer Duty, insurers will be obliged<br />

to design products and services that meet the needs,<br />

characteristics and requirements of a specific customer<br />

segment. However, I don’t see this happening for as long as the<br />

industry continues to cling to a short-term model - exacerbated<br />

by price comparison websites - where there is a relentless drive<br />

to remove valuable cover and deny ever more claims in order to<br />

maintain margins and drive prices further down. <strong>Insurance</strong> isn’t<br />

a product that is designed to be used, and subsequently it isn’t<br />

a product that is generally valued. And you wonder why it’s a<br />

grudge purchase??<br />

We really need to think upside-down and move from shortterm<br />

thinking to long-term thinking if we are truly interested in<br />

creating better outcomes.<br />

Let’s start with preventing claims altogether. Whether it’s my<br />

home or my car, the technology exists to monitor, alert and<br />

mitigate against loss. However, no home insurer wants to cover<br />

the cost of additional hardware to monitor leaks or improve<br />

security, both of which hold the key to better outcomes. The<br />

margins simply aren’t there on an annual policy, where<br />

customers are given no reason not to churn.<br />

But what if we thought long-term? As a customer, I would<br />

willingly buy an insurance-backed product where the focus is<br />

on prevention first and claim second, where the insurer could<br />

purchase the hardware leveraging its economies of scale and<br />

spread this over a 36-month policy. What about a service<br />

package option, where a qualified contractor could pro-actively<br />

complete a winter-readiness check to ensure my drains aren’t<br />

blocked? This has the potential for creating great products,<br />

especially if I can achieve peace of mind and see that the cost of<br />

this is cheaper than the alternative. It would also help to avoid<br />

surge/supply chain issues by switching the focus to preventive<br />

maintenance.<br />

Why not go one step further, and create an embedded<br />

insurance product that comes with my mortgage over a 25-year<br />

term? This would align the interests of homeowners, the banks<br />

(who have a financial interest in the value of the property) and<br />

the insurers - allowing the cost to be shared equitably across all<br />

three parties and creating a possible framework for investment<br />

in climate change measures, action that we know we’ll all need<br />

to take but don’t currently factor into our pricing.<br />

As a motorist, I’d also be prepared to buy an insurance backed<br />

product that includes roadside assistance for when my tyre<br />

does get a flat - as well as a smart repairer that could remove<br />

dents and scratches to make my car look like new.<br />

At the moment, I don’t see an insurance sector that wants to<br />

develop genuinely valuable products and services. Everything<br />

we do tells me the opposite. We seem prepared to create<br />

products that don’t offer great value in order to remain<br />

‘competitive’ for the next<br />

shareholder update, pushing all<br />

of the hassle onto customers<br />

and forcing them to sort out<br />

their own problems. If this is the<br />

case, Consumer Duty seems to<br />

be another opportunity to keep<br />

everyone talking a good talk,<br />

without ever having to confront<br />

the real issue.<br />

Time for change, anyone?<br />

Do let me know your thoughts -<br />

michael.lewis@claimtechnology.co.uk.<br />

Michael Lewis,<br />

CEO, Claim Technology<br />

MODERN INSURANCE | 47


I Love Claims<br />

www.iloveclaims.com<br />

Claims Essentials<br />

RISK &<br />

COMPLIANCE<br />

15 November 2023<br />

etc Venues, Manchester<br />

Consumers - more than just a duty<br />

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30 November 2023<br />

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FEATURES<br />

The Unintended Consequences<br />

of Consumer Duty<br />

The Financial Conduct Authority’s Consumer Duty came into force on 31 July 2023. However,<br />

barely two months since its introduction, there are already worrying signs of unintended<br />

consequences.<br />

Consumer Duty requires firms to put<br />

customers first in every area of their<br />

business, as well as providing proof of<br />

having done so.<br />

Widely regarded as one of the most<br />

substantial regulatory changes to impact<br />

the insurance industry for decades,<br />

the regulations have demanded many<br />

insurers completely transform their<br />

claims strategies, products and selling<br />

policies in order to provide ‘fair value’ to<br />

customers.<br />

However, while the new regulations<br />

are no doubt well-intentioned, the<br />

ramifications could spell bad news for<br />

both insurers and policyholders alike.<br />

Crack down<br />

With the Financial Conduct Authority<br />

(FCA) promising to crack down on<br />

companies that fail to comply, the<br />

pressure is being applied to those<br />

working within the insurance sector.<br />

Already facing a severe skills shortage<br />

following the ‘Great Resignation’ that<br />

came about during and following<br />

COVID-19, insurers could find themselves<br />

facing an even greater challenge around<br />

staff retention.<br />

A study conducted by CoreData back<br />

in August found that 11% of financial<br />

advisors in the UK said that they were<br />

considering leaving the industry as a<br />

direct consequence of Consumer Duty.<br />

Worryingly, 35% said it was having a<br />

negative effect on their mental health,<br />

while 63% said it was hindering their<br />

ability to do their job. Nearly half thought<br />

the new regulations would do more harm<br />

than good.<br />

Fall-out<br />

If these findings are mirrored in the<br />

insurance sector, the fall-out could<br />

be stark. According to the Office of<br />

National Statistics, there were more<br />

than five vacancies for every 100 jobs in<br />

the sector in the second quarter of last<br />

year, while The Skills Shortages Report,<br />

published by ECI, found that insurers<br />

were facing the biggest recruitment<br />

challenge in the UK, with just 570<br />

LinkedIn searches per month compared<br />

with over 46,000 job advertisements.<br />

However, the FCA has insisted that<br />

recruitment and retention problems will<br />

not be considered a mitigating factor in<br />

non-compliance, warning insurers that<br />

they need to ‘manage the issue before<br />

problems occur’.<br />

Resilience<br />

In a letter to CEOs last month, Matt<br />

Brewis, the FCA’s Director of <strong>Insurance</strong>,<br />

warned that a lack of operational<br />

resilience could impact an insurer’s<br />

ability to meet Consumer Duty<br />

standards.<br />

He said, “A significant part of our<br />

activity over the next two years will be<br />

to test firms against our priorities and<br />

expectations. We will also continue to<br />

use data to identify outliers and, where<br />

firms are not meeting our rules and<br />

expectations, we will take action”.<br />

Meanwhile, another unintended<br />

consequence of Consumer Duty could<br />

be higher prices for customers, with<br />

some experts suggesting that the<br />

operational costs of meeting the new<br />

regulations will be passed down.<br />

Who pays?<br />

Discussing Consumer Duty at the Defaqto<br />

Smarter Financial Decisions Conference<br />

in September, Jeffrey Mushens, Technical<br />

Policy Director at The Investing and<br />

Saving Alliance, said: “Who pays? It is<br />

always the customers. The firms will pay<br />

the initial costs, but this will eventually get<br />

passed onto the customers”.<br />

A report prepared for the FCA<br />

Practitioner Panel in 2021 appears to<br />

have accepted this. It acknowledged<br />

that complying with Consumer Duty<br />

would add ‘significant cost’ to firms,<br />

and said that ‘these costs will be passed<br />

on in some form, to either shareholders<br />

or customers. Where markets are<br />

competitive, the balance is likely to tilt<br />

more towards these costs ultimately<br />

being borne by customers.’<br />

I Love Claims is set to explore the<br />

implications of the new consumer<br />

regulations and much more at its<br />

forthcoming Risk and Compliance themed<br />

event, ‘Consumers – more than just a<br />

duty’, taking place on 15th November in<br />

Manchester.<br />

Email Rachael Hunt to find out more:<br />

rachael@iloveclaims.com<br />

MODERN INSURANCE | 49


SHAPING THE FUTURE OF<br />

SUSTAINABLE MOBILITY<br />

Take charge at europcar.co.uk/business<br />

or call 0371 384 0140


FEATURES<br />

Can the insurance<br />

sector help to<br />

accelerate the<br />

adoption of EV?<br />

James Roberts, Head of <strong>Insurance</strong> Sales, Europcar Mobility Group UK, discusses how vehicle rental can<br />

support the insurance industry as it strives to match customer ambitions towards zero emissions.<br />

To help customers make those ‘good financial<br />

decisions’, businesses must provide a range of<br />

suitable options from which they can choose.<br />

However, sole supplier agreements make this<br />

difficult to achieve in the insurance space. Insurers<br />

working with only one CHO or replacement<br />

vehicle partner are at risk of breaching their<br />

Consumer Duty if there’s a perception that the<br />

customer is not being offered the best choice for<br />

their needs.<br />

As consumer demand for electric vehicles<br />

(EVs) continues to grow, the insurance sector is<br />

shifting rapidly to keep pace. Policies have been<br />

amended to suit electric and hybrid models,<br />

and repair networks have updated training and<br />

suppliers to ensure that they can work safely<br />

on the increasingly electrified car parc. What<br />

is proving more of a challenge, however, is<br />

providing electric vehicles as replacements while<br />

a policyholder’s own EV is being repaired after<br />

an accident.<br />

The cost and availability of EVs are two significant<br />

blockers, especially for those insurers with sole<br />

supplier contracts. Many such insurers have been<br />

forced to scrap like-for-like vehicle replacement<br />

policies. In light of the COVID-19 supply<br />

shortage, they were left grateful to be able to offer<br />

customers any kind of temporary vehicle at all.<br />

If an insurer is unable to offer the best solution<br />

for the needs of the customer, they could now<br />

be at risk of breaching their Consumer Duty<br />

requirements. And, as the electric car parc grows,<br />

the demand for like-for-like vehicle replacement<br />

should be the default – not the exception.<br />

Meeting policyholders’<br />

expectations<br />

We recently commissioned a study amongst<br />

electric car drivers, and found that 90% would<br />

expect an EV replacement in the event of their<br />

own vehicle being out of commission after an<br />

accident 1 . Insurers unable to meet this expectation<br />

risk damaging delicate customer relationships. The<br />

Motor Ombudsman is already starting to see a<br />

small rise in the number of EV complaints – with<br />

the level of service delivered by businesses, and<br />

problems encountered at the point of purchase,<br />

highlighted as key concerns 2 . As EV adoption<br />

moves beyond the early adopters and becomes<br />

a mainstream choice, insurers are going to need<br />

to keep up the pace or face reputational risk.<br />

There are already around 840,000 fully electric<br />

cars and 520,000 plug-in hybrids on UK roads 3 ,<br />

making up more than 20% of the car parc and<br />

representing a significant number of customers<br />

who are likely to expect an EV replacement.<br />

Drivers of ICE vehicles may also be tempted to<br />

use the opportunity to test-drive electric if the<br />

option was available for their replacement.<br />

Electric rental<br />

As the industry adapts to the growing electric car<br />

parc, Europcar Mobility Group UK is working<br />

closely with insurance providers, repair networks<br />

and other key players to help them deliver<br />

continued customer satisfaction and retention.<br />

We are already committed to helping drivers<br />

adapt to the new drivetrain as soon as possible<br />

by providing easy access to EV rental. That<br />

commitment now extends to replacement vehicles<br />

through insurance providers.<br />

Insurers selecting Europcar as their EV<br />

replacement partner will have the confidence<br />

that our network is increasingly electrified. More<br />

than 200 charging points are already installed at<br />

rental locations across the UK. Plus, each driver<br />

benefits from a comprehensive vehicle handover<br />

and support with charging instructions, alongside<br />

a growing team of specialist Certified Electric<br />

Vehicle experts on hand at many locations to<br />

help customers as they get to know their rental<br />

vehicle.<br />

We provide a viable alternative to the sole<br />

supplier conundrum, too. For insurance providers<br />

who have historically opted for sole supply<br />

contracts, moving away from this model will<br />

ensure that they have contingency against vehicle<br />

supply gaps, resulting in minimised friction from<br />

the claims process.<br />

Understanding the customer<br />

experience<br />

Drivers and businesses are increasingly<br />

prioritising sustainability and zero emissions<br />

mobility, and insurers need to be able to respond<br />

to these key issues. By working collaboratively, we<br />

can help with valuable insights and learnings as<br />

our fleet of electric vehicles grows.<br />

For example, a Europcar team took part in a<br />

1,200-mile EV Rally earlier this year, tracking<br />

across the British Isles from Cardiff to London,<br />

Edinburgh, Belfast and Dublin. This unique<br />

experience provides us with invaluable insights,<br />

which are helping us to better serve customers<br />

as they look for more environmentally friendly<br />

vehicles. It also underlined the importance of<br />

gaining real-world experience with a range of<br />

options available, from a rental of a few days to<br />

several months, and with the facility to try different<br />

makes and models.<br />

Although the vehicle landscape is changing,<br />

motorists will appreciate an insurance provider<br />

that is flexible and able to offer innovative<br />

solutions to sustainable driving. Working with<br />

the right vehicle partner is a crucial step towards<br />

making this a reality within the insurance industry.<br />

For further information, visit www.europcar.co.uk/<br />

business<br />

James Roberts,<br />

Head of <strong>Insurance</strong> Sales,<br />

Europcar Mobility Group UK<br />

1<br />

Survey via Vypr of 228 EV owners, conducted September 2023<br />

2<br />

The Motor Ombudsman- https://www.themotorombudsman.org/<br />

press-releases/tmo-reports-a-small-rise-in-ev-complaints-from-consumersin-q2-2023<br />

3<br />

ZapMap- https://www.zap-map.com/ev-stats/ev-market<br />

MODERN INSURANCE | 51


mins with...<br />

What is your most memorable career achievement?<br />

Q<br />

A<br />

So far, my most memorable career achievement has been<br />

setting up two organisations: Gambit Partners (a sales<br />

and marketing firm), and iCAN – The <strong>Insurance</strong> Cultural<br />

Awareness Network (a professional network built to support the<br />

careers of ethnic minorities in the insurance industry). iCAN now<br />

has over 6,500 members, and this continues to grow all the time.<br />

Building two organisations from the ground up has been a huge<br />

learning experience and I’ve had so much fun doing it, so much<br />

so that I will be launching my third business in the New Year!<br />

What has been the most valuable piece of advice<br />

you’ve received?<br />

Q<br />

From my Dad, Ashwin Mistry: “Always have a plan”.<br />

A<br />

This ingrained a mentality in me around having goals and<br />

plans, and ultimately a path to follow from a young age.<br />

It really makes you think differently about decisions as you go<br />

through life, as you’re thinking about how your decisions in the<br />

present affect the outcomes of the future.<br />

What has been the key positive or negative impact of<br />

change in your area of the market?<br />

Q<br />

My core area of the market is schemes. The main positive<br />

change in this area has been the increased use of, and<br />

trust of, technology.<br />

A<br />

Ajay Mistry<br />

The growth of the digital buying journey has evolved, and with<br />

schemes being able to provide more competition and benefit<br />

to the customer, there has never been a better time to provide<br />

solutions to small and micro-business clients.<br />

Title: Founder and Director, Gambit Partners and Co-Founder and Co-Chair, iCAN<br />

(The <strong>Insurance</strong> Cultural Awareness Network)<br />

The negative impact is the lack of quality advice. Access to<br />

quality advice for small business owners has not advanced at the<br />

same pace as technology. This has led to so many businesses<br />

being wrongly insured, not understanding the value of insurance<br />

and not being provided with adequate solutions to their evolving<br />

needs in what is a fast-moving business landscape.<br />

What three items would you put on display in a<br />

museum of your life and why?<br />

Q<br />

A<br />

My mobile phone, as it does everything for me and it’s my<br />

connection to friends and family, as well as my business<br />

partners and contacts. It also hosts my LinkedIn and<br />

Social Media profiles (which are very important to me) and also<br />

captures photos of everything I do!<br />

I’d also include my trusty suitcase to represent travel. Having<br />

done stints in Sweden and Spain, as well as all the great times I<br />

have spent abroad, this is a huge part of my life.<br />

Thirdly, I’d include an iCAN Role Models book (or any iCAN<br />

merch!) to represent iCAN. With the amazing events we run, the<br />

jobs board we have built, the self-serving mentoring platform,<br />

the support we give to company Employee Resource Groups, the<br />

support we give across the country in London, Birmingham and<br />

Manchester – I am so proud of everything my team and I have<br />

built. We help so many people each month, so it needs to go in<br />

there to represent the significance of what iCAN means to me<br />

and so many others.<br />

What three guests would you invite to a dinner party?<br />

Q<br />

Sir Alex Ferguson – as well as being a huge Man Utd fan,<br />

I would love the chance to get his views and advice on<br />

leadership.<br />

A<br />

Jane Lu – she is an Australian entrepreneur who has built a<br />

multi-million dollar empire under her banner of Showpo. From<br />

her humble beginnings though to where she is now, she has<br />

a lot to teach me about business and life. Plus, she is a wine<br />

connoisseur who has built a network of thousands of others who<br />

are interested in the study of wine – which would really help with<br />

the food!<br />

Gordon Ramsey – an excellent dinner party needs excellent<br />

food! Gordon is also a very successful businessman and has built<br />

several businesses from the ground up, so it would be great to<br />

get his thoughts on building and scaling businesses.<br />

Market-Leading Outsourced Claims Services<br />

www.carpentersgroup.co.uk<br />

MODERN INSURANCE | 53


INSURTECH<br />

INSUR.<br />

TECH.<br />

TALK<br />

MODERN INSURANCE | 55


INSURTECH<br />

WELCOME<br />

Greetings, and welcome<br />

to Insur.Tech.Talk!<br />

In this issue, we are tackling the complex issue of Consumer Duty in <strong>Insurance</strong>.<br />

After all, we are in the protection business! We need to be obsessive about<br />

the consumer experience, and nothing is more important than protecting<br />

the interests of individuals and businesses who work with us to purchase the<br />

necessary insurance products and services.<br />

The new Consumer Duty promotes confidence, trust, and fairness in the<br />

insurance industry by ensuring that insurers do not waver in their focus<br />

on the needs and expectations of the customer. In the forthcoming set of<br />

interviews, we will address Consumer Duty from the perspective of fair and<br />

reasonable claims handling, appropriate consultation and advice on products<br />

and services, clear and fair communication, data protection and privacy, as<br />

well as the role of the regulators.<br />

Finally, I would like to thank my wonderful panellists for their kind<br />

contributions to this issue. This edition has been made possible due to the<br />

knowledge and expertise of the following:<br />

• Farooq Sheikh, Global Head of <strong>Insurance</strong>, Unqork<br />

• Brent Williams, Founder and CEO, Benekiva<br />

• Juan Mazzini, Director of <strong>Insurance</strong> Practice APAC, EMEA and LATAM,<br />

Celent<br />

• Meredith Barnes-Cook, Partner, ReSource Pro Consulting<br />

• Ron Rock, Managing Director - Financial Services, JobsOhio<br />

Until next time, happy reading!<br />

Megan Kuczynski,<br />

President,<br />

Insurtech Insights<br />

56 | MODERN INSURANCE


INSURTECH<br />

Unqork<br />

Farooq Sheikh,<br />

Global Head of <strong>Insurance</strong>, Unqork<br />

QFarooq, the UK’s Financial Conduct Authority<br />

(FCA) recently implemented Consumer Duty<br />

Initiatives which require financial institutions to<br />

proactively deliver ‘good outcomes’ for all.<br />

Many have called this initiative a ‘paradigm shift’ for<br />

the industry. How is Unqork and its codeless platforms<br />

aligned to Consumer Duty, and how can it improve<br />

consumer outcomes? How has technology increased the<br />

customer’s expectations?<br />

AAcross insurance and financial services, consumers<br />

are increasingly aware and interested in a higher<br />

number of digital services, including self-service<br />

capabilities. Empowering consumers and financial services<br />

institutions to deliver on a seamless customer experience,<br />

as well as accelerated onboarding and servicing, is at<br />

the heart of Unqork’s mission to leverage our codeless<br />

technology. This enables better outcomes for consumers<br />

across Financial Services, <strong>Insurance</strong>, Healthcare and Public<br />

Enterprise.<br />

QHow has technology enhanced the customer’s<br />

journey in the claims process? What are some of<br />

the obstacles that need to be overcome in the<br />

claims process as it relates to Consumer Duty?<br />

ASeamless claims are the basis of an insurer’s<br />

promise to its consumers, especially during times<br />

of need. Unqork’s codeless Claims Workbench<br />

is an effort to accelerate insurers’ efforts to transform<br />

claims management technology as it undergoes massive<br />

transformation - with insurers investing in transforming<br />

the value chain from FNOL to adjudication to managing<br />

litigation, subrogation and associated processes for a<br />

seamless customer experience.<br />

Q<br />

As<br />

policyholders and brokers increasingly seek<br />

digital self-service options, when interacting with<br />

an insurance company, what are some of the<br />

more novel technologies you are seeing come to<br />

market?<br />

AWith the rise of Generative AI across industries,<br />

we are seeing an increased number of novel<br />

approaches to enhance self-service options. From<br />

rapid summarisation of policy documents, to extraction of<br />

data elements from submissions, to smart chatbots that<br />

facilitate self-service capabilities, the impact of Generative<br />

AI is truly transformative. I’m certain that this will continue<br />

to be felt across the industry for some time.<br />

QWhat steps can insurance companies take to ensure<br />

that consumers have access to appropriate coverage<br />

and remain protected against unfair and deceptive<br />

practices?<br />

AInsurers have a responsibility to protect consumers<br />

by providing fair and appropriate coverage from<br />

insurable risks. This involves ensuring that the<br />

products are designed with consumers in mind. All functional<br />

areas - including distribution, underwriting and claims – must<br />

be focused on the needs of the consumer. Seamless digital<br />

capabilities provide a significant accelerator in this journey,<br />

and leading insurers are leveraging digital capabilities<br />

aggressively to ensure consumer access to the appropriate<br />

coverage, as well as protection against deceptive practices.<br />

QAny personal anecdotes to share as a consumer in<br />

terms of what insurers are doing right, and what<br />

needs to change?<br />

AAnyone who has lived through a catastrophic<br />

hurricane can attest to an insurer’s magical ability<br />

to protect communities. Hurricane Sandy was one<br />

example of how insurers were able to step in to help those<br />

affected. Many people in the New York area were impacted,<br />

but they were also supported by their insurers to re-emerge<br />

stronger after the devastating losses.<br />

Farooq Sheikh is the Global Head of <strong>Insurance</strong> for<br />

Unqork, working with global insurers, brokers and<br />

technology providers.<br />

Unqork is the leading code-less platform, which<br />

enables large complex clients to digitize customer<br />

experiences, create leading edge buying journeys, and<br />

automate internal processes. Unqork has pioneered<br />

the ‘code-less architecture’ approach, which allows<br />

clients to accelerate the speed of digital transformation,<br />

particularly focused on areas that require leading edge<br />

presentation, orchestration, and integration capabilities.<br />

Before Unqork, Farooq was at Oliver Wyman, where<br />

he was a Partner in the <strong>Insurance</strong> and Digital practices.<br />

He led go-to-market for multiple platforms, including<br />

Reinventing <strong>Insurance</strong> and Legacy migrations.<br />

Farooq completed his Executive Education from<br />

INSEAD and The Wharton School of Business. He is a<br />

qualified Actuary and CFA Charter holder.<br />

MODERN INSURANCE | 57


INSURTECH<br />

Benekiva<br />

Brent, how have you seen technology increase the<br />

customer’s expectations in recent years?<br />

Q<br />

A<br />

Technology has fundamentally changed the way in<br />

which a consumer interacts with businesses, including<br />

insurance companies. Having previously worked as<br />

a financial advisor, I’ve witnessed claimant challenges<br />

firsthand as they navigate the complicated claims process.<br />

Sometimes, due to a poor claims experience, I would lose<br />

the opportunity to retain claimants as customers. This<br />

underscores the critical importance of providing a seamless<br />

and empathetic claims journey.<br />

With the emergence of Amazon-like service expectations,<br />

consumers have come to expect immediacy and a high level<br />

of service in all aspects of their lives, including insurance. They<br />

want easy access to policy information, quick responses to<br />

queries, and transparent processes. Technology has raised<br />

the bar for insurers to provide efficient, personalized, and<br />

accessible services that meet these evolving expectations.<br />

Q<br />

A<br />

How has technology enhanced the customer’s journey<br />

in the claims process? What are some obstacles<br />

to overcome in the claims process as it relates to<br />

Consumer Duty?<br />

Technology has undeniably transformed the landscape<br />

of insurance claims, offering numerous advantages<br />

such as faster claims reporting, real-time updates,<br />

and the convenience of digital document submission. These<br />

innovations have empowered consumers, granting them<br />

greater control over their claims journey, and ensuring they<br />

receive timely, transparent information.<br />

However, amid the whirlwind of automation and digitalization,<br />

one critical aspect remains indispensable—the human touch.<br />

In the quest for efficiency and automation, it’s easy to forget<br />

that behind every claim lies a unique individual with their own<br />

set of concerns and emotions. While technology streamlines<br />

processes, it’s the human interaction that infuses empathy,<br />

understanding, and personalized care into the exchange.<br />

Striking the right balance between automation and genuine<br />

human connection is the key to ensuring that claimants not<br />

only navigate their journey seamlessly, but also receive the<br />

stellar and exceptional service they truly deserve.<br />

Additionally, we must make inaccessible data easily accessible<br />

to enable frictionless processing and payouts. Many insurers<br />

still rely on legacy systems that make it challenging to<br />

access and utilize customer information effectively. This<br />

inaccessibility leads to overwhelming manual processes<br />

and workarounds that must be navigated by associates.<br />

To fulfill Consumer Duty effectively, we must prioritize the<br />

automation of these cumbersome manual tasks. This not only<br />

improves efficiency, but also ensures that claims are handled<br />

consistently and fairly, aligning with our commitment to the<br />

customer experience.<br />

QCongratulations on the launch of Portal360. It’s great<br />

to see your technology evolving to meet consumer<br />

needs. Could you explain how the increased<br />

functionality to accommodate third-party stakeholders in<br />

Portal360 will enhance the claimant’s experience?<br />

AThank you for your kind words. Portal360 is a<br />

significant milestone for us, and I’m excited to<br />

share how it benefits claimants and third-party<br />

stakeholders alike.<br />

Portal360, driven by Benekiva’s advanced technology,<br />

offers a localized hub where claimants and stakeholders<br />

can access crucial information and conduct transactions<br />

seamlessly. For claimants, this means they can conveniently<br />

access notifications, statements and correspondence, all<br />

within the intuitive Portal360 interface. They can securely<br />

upload documents, set up electronic transfers, and engage<br />

in real-time discussions with our team, all without leaving the<br />

platform. It’s all about putting control in the claimant’s hands<br />

and ensuring a smooth, informed experience.<br />

What’s equally important is the platform’s ability to<br />

foster collaboration. Agents can utilize Portal360 to serve<br />

their clients more effectively, efficiently manage claims,<br />

and seamlessly exchange information. By extending its<br />

functionality to third-party stakeholders, we’re creating<br />

an ecosystem that improves communication, expedites<br />

processes, and ultimately enhances the overall claimant<br />

experience.<br />

Additionally, Portal360 is designed to be user-friendly and<br />

fully configurable to an insurer’s specific needs. This flexibility<br />

ensures a seamless integration with their existing systems.<br />

Through our proprietary Data Configurator and Innovation<br />

Gateway architecture, insurers can effortlessly connect<br />

Portal360 to their legacy systems, policy administration<br />

systems, or third-party administrators - simplifying data<br />

exchange and maximizing the value of their current<br />

infrastructure.<br />

In essence, Portal360 represents a significant leap forward<br />

in beneficiary claim processes, providing an intuitive,<br />

comprehensive, and collaborative platform. We’re confident<br />

that it will make a positive impact on the industry, and help<br />

us to continue our mission when it comes to transforming<br />

insurance claims operations for the better.<br />

58 | MODERN INSURANCE


INSURTECH<br />

QIn your opinion, what are some of the challenges that<br />

insurance companies face in fulfilling their Consumer<br />

Duty?<br />

AWhen it comes to fulfilling Consumer Duty in insurance,<br />

one of the central obligations involves keeping a<br />

promise to policyholders and beneficiaries. That<br />

promise is to pay claims when they’re needed most. To<br />

achieve this, insurers must navigate several challenges that<br />

directly impact the claimant’s experience.<br />

Firstly, transparency is key. Claimants expect clear and<br />

timely updates on the status of their claims. Lack of<br />

transparency or communication breakdowns can deter<br />

claimants from becoming long-term clients, causing<br />

significant stress. Therefore, it’s essential for insurers to<br />

provide a transparent and open line of communication<br />

throughout the claims journey.<br />

On the flip side, there are areas where insurers can enhance<br />

the claims experience, such as the efficiency of the claims<br />

process. Lengthy waiting times for claim payouts can be a<br />

pain point for consumers. In today’s world, where immediacy<br />

is expected, insurers should aim to expedite claims processing<br />

while maintaining accuracy.<br />

I’ve also observed that insurers embracing modern<br />

technology tend to offer a better consumer experience.<br />

Digital platforms that allow easy access to policy information<br />

and the ability to initiate claims online are becoming<br />

increasingly important. However, not all insurers have fully<br />

adopted these technological advancements, which can lead<br />

to disparities in consumer experiences.<br />

For Benekiva media enquiries, please reach out to<br />

Maura Gilson-O’Donnell at maura@benekiva.com<br />

Secondly, lengthy waiting times for claim payouts can be a<br />

major pain point. In today’s fast-paced world, consumers have<br />

come to expect quick, efficient services. Slow or inefficient<br />

claims processing can be a source of frustration for claimants.<br />

Insurers need to streamline their processes, leveraging<br />

technology to expedite claims while maintaining accuracy.<br />

Thirdly, inefficiencies within the claims process can be<br />

a significant hurdle. Manual, paper-based workflows<br />

and outdated systems can lead to errors, delays, and<br />

inconsistencies. To fulfill Consumer Duty effectively, insurers<br />

must embrace modern, automated solutions that enhance<br />

efficiency and provide a seamless claims experience for<br />

the claimant.<br />

Ultimately, insurance companies have a responsibility to<br />

go beyond mere compliance with regulation. They must<br />

uphold policyholder trust and confidence. Addressing<br />

challenges related to transparency, efficiency, and<br />

communication is paramount, as it not only helps retain<br />

clients but also ensures that the claims journey is as stressfree<br />

as possible for the claimant.<br />

QAny personal anecdotes to share as a<br />

consumer in terms of what insurers are doing<br />

right, and what needs to change?<br />

In the realm of insurance claims, carriers share<br />

a common goal: they genuinely want to fulfill<br />

A their obligations and pay claims promptly.<br />

Their focus needs to be on ensuring that the right<br />

claims reach the right recipients.<br />

First and foremost, some insurers have truly<br />

mastered the art of claims handling, placing a<br />

premium on clear and timely communication. As<br />

a consumer, there’s nothing more reassuring than<br />

receiving regular updates and comprehensive<br />

information about the status of your claim, all<br />

without the need to ‘chase it down’. When insurers<br />

excel in this aspect of their service, it accomplishes<br />

two essential objectives. It not only fosters trust<br />

in their customers, but it also alleviates the stress<br />

and uncertainty that can frequently accompany the<br />

claims process. Effective communication stands as a<br />

testament to the insurer’s commitment to providing<br />

exceptional service during a critical moment in their<br />

claimant’s lives.<br />

Brent Williams,<br />

Founder and CEO, Benekiva<br />

MODERN INSURANCE | 59


INSURTECH<br />

Celent<br />

QJuan - I have followed your work<br />

for years, and Celent are one of<br />

my ‘go-to’s’ in terms of market<br />

intelligence. I would love to know<br />

how you’ve seen technology<br />

increase the expectations of the<br />

customer in recent years?<br />

ATechnology has significantly<br />

increased customer expectations<br />

in the insurance industry.<br />

Customers now have more options<br />

and convenience, and they expect<br />

insurance companies to offer a seamless,<br />

personalized experience across all<br />

channels - including online, mobile, and<br />

in-person. They want to be able to easily<br />

find what they are looking for, receive<br />

personalized recommendations, and<br />

have their questions answered quickly<br />

and accurately. Additionally, customers<br />

expect insurance companies to be<br />

available 24/7 and to provide fast and<br />

efficient service. Technology has made<br />

it easier for customers to compare<br />

insurance policies and prices, which<br />

has increased their expectations for<br />

competitive pricing and high-quality<br />

coverage, too.<br />

However, insurance encompasses many<br />

lines of business and risks, which affect<br />

expectations and perceptions of how the<br />

customer journey should be set up.<br />

The expectations of customers in the life<br />

insurance industry may differ from those<br />

in other insurance sectors, such as auto<br />

or commercial insurance. In the case of<br />

life insurance, customers may expect<br />

a more empathetic and personalized<br />

experience, as they are dealing with<br />

sensitive and emotional issues related<br />

to their own mortality or that of a<br />

loved one. They may also expect clear<br />

and transparent communication from<br />

their insurance provider, as well as a<br />

streamlined claims process that is easy<br />

to navigate during a difficult time.<br />

On the other hand, auto insurance<br />

customers may have different<br />

expectations. They may expect a 100%<br />

digital self-service experience, with ease<br />

to compare prices and options, no-touch<br />

claims, and online support. Customers<br />

of commercial insurance, particularly<br />

with regards to complex risks, expect<br />

their insurance provider to have a deep<br />

understanding of the specific risks and<br />

challenges associated with their industry.<br />

They are also more likely to rely on a<br />

broker or risk specialist to determine the<br />

right type of coverage.<br />

Q<br />

How has technology enhanced<br />

the customer’s journey in the<br />

claims process?<br />

Technology has enhanced the<br />

customer’s journey in the claims<br />

Aprocess mainly by providing more<br />

efficient and streamlined processes.<br />

These days, customers can expect to file<br />

claims online, track the status of their<br />

claims in real-time, and receive updates<br />

via email or text message. They can<br />

also expect insurers to provide fast and<br />

accurate relief for their loss.<br />

For example:<br />

• Parametric insurance provides a<br />

no-touch experience for customers;<br />

no FNOL is required, and payments<br />

are made against meeting a specific<br />

threshold, as defined in the insurance<br />

contract.<br />

• The use of AI (eg. machine vision<br />

algorithms) can analyze images<br />

or videos of damaged property,<br />

automatically assessing the extent<br />

of the damage. Likewise, the use<br />

of sensor-provided data (by itself,<br />

or in combination with images/<br />

video) could also help to speed up<br />

the claims process and reduce the<br />

need for manual intervention. With<br />

the use of chatbots - and now with<br />

the recent popularity of Generative<br />

AI - we should expect improvements<br />

in claims support. This will provide<br />

policyholders with clear and easily<br />

accessible information regarding their<br />

claims.<br />

• Fraud detection solutions, augmented<br />

by AI and access to multiple data<br />

sources, provide insurers with better<br />

mechanisms to identify and expedite<br />

non-fraudulent claims. By analyzing<br />

images and videos of the claim event,<br />

machine vision algorithms can identify<br />

patterns and anomalies that may<br />

indicate fraudulent activity. This can<br />

help insurers to detect and prevent<br />

fraud, which can ultimately lead to<br />

lower costs and better outcomes for<br />

policyholders.<br />

• Geospatial data can be used to<br />

identify the location of a property<br />

and assess the risk of damage from<br />

natural disasters, such as floods,<br />

hurricanes, and wildfires. Aerial<br />

imagery can then be used to assess<br />

the extent of damage. By using drones<br />

or other aerial vehicles to capture<br />

images of the affected area, insurers<br />

can get a more accurate picture<br />

of the damage and determine the<br />

appropriate amount of compensation<br />

to offer. This can help to speed up<br />

the claims process and ensure that<br />

policyholders receive fair and accurate<br />

compensation for their losses.<br />

What are some obstacles to<br />

overcome in the claims process<br />

Qas it relates to Consumer Duty?<br />

Customers may be required<br />

(as per regulatory mandate, in<br />

Asome cases) to provide detailed<br />

information and documentation to<br />

support their claims, which can be timeconsuming<br />

and frustrating. Additionally,<br />

customers may be required to take<br />

certain actions, such as mitigating<br />

damages or providing additional<br />

information, in order to receive their<br />

claim payout. These requirements can<br />

be confusing or difficult to navigate,<br />

particularly for customers who are<br />

dealing with the stress and uncertainty<br />

of a loss.<br />

Insurers can take several steps to<br />

improve the customer experience<br />

related to Consumer Duty in insurance,<br />

such as:<br />

• Simplifying the application process<br />

by using online forms and other tools.<br />

This will make it easy for policyholders<br />

to provide the necessary information,<br />

and can help to reduce the likelihood<br />

of errors and omissions, improving the<br />

overall customer experience.<br />

• Offering guidance and support to<br />

policyholders who are unsure about<br />

their duty of disclosure, or other<br />

such obligations under the insurance<br />

contract. This can help to ensure that<br />

policyholders are able to provide<br />

accurate and complete information,<br />

building trust and confidence in the<br />

insurer.<br />

• Using technology and data to<br />

automate and streamline the<br />

process of collecting and analyzing<br />

information from policyholders. This<br />

can help to reduce the time and effort<br />

required to complete the application<br />

process, and improve the accuracy of<br />

the data to assess the risk and manage<br />

the claims process.<br />

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INSURTECH<br />

QAs policyholders and brokers<br />

increasingly seek digital<br />

self-service options, when<br />

interacting with an insurance<br />

company, what are some of the<br />

more novel technologies you are<br />

seeing come to market?<br />

ASeveral technologies can help<br />

to improve the customer’s<br />

experience of policyholders and<br />

brokers. However, there’s a new way of<br />

looking at the customer value equation<br />

in a world of customer-centric design.<br />

Delivering on this requires a wide<br />

variety of digital capabilities, elements<br />

that aren’t typically found in an insurer’s<br />

core application architecture. At Celent,<br />

we’ve developed a framework to help<br />

insurers think about how to digitize<br />

the customer experience, where the<br />

‘customer’ could be the policyholder, a<br />

broker, an agent, or an employee.<br />

From a policyholder perspective, the<br />

framework proposes these areas of<br />

focus for fast, easy, and cost-effective<br />

experiences:<br />

• Know me. Use the technology<br />

and data available to understand<br />

my preferences, my situation and<br />

life events, my coverage, and my<br />

policy-related information. This is a<br />

360-degree view of me as a client, so<br />

in any interaction, I can trust you to<br />

know what’s best for me.<br />

• Help me to protect myself. If you<br />

know me and know others like me,<br />

you should provide me with products<br />

that suit my needs. Advise me on<br />

emerging risks, and any blind spots<br />

that I might possess (since I am not<br />

an insurance expert). Advice, realtime<br />

decision engines, and the use of<br />

geospatial data are all good examples<br />

of technology that can help to better<br />

protect the policyholder. Investing<br />

against cybercrime is another means<br />

of protection, as well as the data<br />

stored within IT systems.<br />

• Help me to prevent losses. I don’t<br />

want to suffer a loss and neither do<br />

you, the insurer. With the knowledge<br />

and technology you have available,<br />

help me to prevent the loss in<br />

the first place. Move from a pure<br />

indemnity value proposition to one<br />

where you become my ally in loss<br />

prevention. IoT, sensors, wearables,<br />

and cyber protection for personal<br />

and commercial lines are all examples<br />

of technologies that can help prevent<br />

losses.<br />

• Help me to recover from losses. Do<br />

it fast, do it right, and help me get<br />

back on my feet as soon as possible.<br />

Machine vision and aerial imagery are<br />

two examples of useful technology<br />

to help with this. A good claims<br />

management system that provides<br />

ease of use and clear communications<br />

through the claims process is tablestakes.<br />

Designing products with a notouch<br />

claims process is another way to<br />

approach a fast recovery from losses.<br />

• Talk to me. Use the right channel,<br />

and consider the stage of the journey<br />

and my preferences. This could<br />

be automated assistance, such as<br />

chatbots or virtual CSRs, or messaging<br />

such as SMS or WhatsApp. For<br />

complex risks, video conferencing with<br />

an expert is a great medium. For easyto-manage<br />

situations, this could be<br />

managed via a mobile app or access<br />

to a service chatbot.<br />

• Involve me. With more empowered<br />

and knowledgeable customers, there’s<br />

a need and an opportunity to involve<br />

them in many steps of the journey.<br />

This includes easy-to-use tools for<br />

customizing an insurance product,<br />

right the way through to self-service<br />

claims management.<br />

QWhat are insurers are doing<br />

right, and what needs to change?<br />

AThree examples of good<br />

customer experience immediately<br />

come to mind:<br />

1. My boat insurer tracks weatherrelated<br />

risks and keeps me informed.<br />

They also tell me what I should do to<br />

prevent losses, or at least mitigate the<br />

loss severity.<br />

2. Providing very little information in<br />

order to obtain an auto insurance<br />

quote. For example, the vehicle<br />

information is populated based on<br />

my home address. This is possible<br />

because the insurer is accessing<br />

vehicle-related data and preempting<br />

this information on the form. While<br />

this is common in the US, it’s not the<br />

norm in many countries in the world.<br />

3. On a recent trip to Singapore,<br />

I encountered an embedded,<br />

parametric, contextual insurance<br />

offering provided by a ride-hailing<br />

app, which covered the risk of delay<br />

in my trip. This was a one-click sale<br />

experience, and if I had a claim, the<br />

experience would have triggered an<br />

automatic payout without the need to<br />

submit a FNOL.<br />

There are still many things which<br />

need to change, but the industry is<br />

certainly headed in the right direction.<br />

Technology is redefining the art of the<br />

possible, and I would advise insurers<br />

to look into Celent’s framework for<br />

digitizing the customer experience. It<br />

will provide a simple yet powerful tool<br />

to assess areas for improvement beyond<br />

their traditional customer journey.<br />

Juan is a Director at Celent and Head<br />

of <strong>Insurance</strong> Practice for EMEA,<br />

APAC, and LATAM. He is responsible<br />

for global research and advice to<br />

C-level executives in the financial<br />

services industry, on themes such<br />

as fintech, insurtech, innovation,<br />

emerging technologies, and business<br />

transformation. He has been involved<br />

in the launch and evolution of<br />

various innovative initiatives and<br />

business models in the financial<br />

services industry, including the<br />

first reinsurance exchange in Latin<br />

America, a direct insurance brand in<br />

the .com era, and most recently, the<br />

design and construction of a digital<br />

direct insurer.<br />

Juan Mazzini,<br />

Head of <strong>Insurance</strong> Practice APAC,<br />

EMEA, LATAM, Celent<br />

MODERN INSURANCE | 61


INSURTECH<br />

ReSource Pro<br />

Consulting<br />

Meredith, great to catch up! I’d like to start<br />

by talking about how you’ve seen technology<br />

Qincrease consumer expectations in recent years?<br />

Thank you for this opportunity to chat about<br />

such an important topic, Megan.<br />

AI believe our expectations as insurance customers are<br />

continuously shaped by our experiences in all other<br />

aspects of our lives, from retail and dining to travel<br />

and entertainment, in addition to work. The role of<br />

technology in our daily lives began to shift about thirty<br />

years ago with the emergence of the pioneers of digital<br />

consumer services, like Amazon, eBay, PayPal, Open<br />

Table, Travelocity, and Netflix. Today, I can pay for my<br />

coffee with a tap of my phone or my watch. Thanks to<br />

innovation, I don’t even need to carry cash or a credit<br />

card. But technology driven by necessity is a factor, too.<br />

The pandemic lockdown required the use of technology<br />

to get groceries and medications, even for those that<br />

were not otherwise digitally included.<br />

What does the insurance customer of today expect?<br />

They expect requesting and receiving service to be<br />

easy. They expect transparency, knowing where they are<br />

in the service journey, what happens next, and when,<br />

including proactivity. They expect the option of selfservice<br />

through the digital channel of their choice, and a<br />

clear path to reach a person.<br />

How has technology enhanced the customer’s<br />

journey in the claims process? What are some<br />

Qobstacles to overcome in the claims process as it<br />

relates to consumer duty?<br />

Beginning with the first notice of loss or first<br />

report of injury, we’ve come a long way from<br />

A24x7x365 call centers and mobile apps to report<br />

an accident. Today, there are telematics solutions that<br />

detect impact and initiate the first notice of loss, and<br />

wearables that measure and alert on ergonomic risk<br />

factors to prevent a work-related injury. Technology<br />

has accelerated the claim adjustment journey, too.<br />

Video live streaming can get an adjuster virtually<br />

on-site immediately to begin assessing a serious loss.<br />

Telemedicine connects injured workers to medical<br />

professionals for rapid care direction. AI photo<br />

estimating can generate an immediate repair estimate,<br />

eliminating the need for a physical appraisal. Digital<br />

payments and real-time transactions get money into the<br />

customer or claimant’s mobile wallet quickly, without<br />

the friction of time and effort required for paper checks.<br />

Omnichannel conversational AI solutions meet the<br />

customer where they are, with proactive claim status<br />

updates and maximum ease to get their questions<br />

answered quickly.<br />

Technology offers powerful options, making the<br />

experience easy and ensuring end-to-end data privacy.<br />

It also guarantees compliance with all applicable<br />

regulations within and beyond those in insurance. While<br />

automation can streamline an entire claim journey (or<br />

pieces of that journey), we should never be so bold as<br />

to assume it’s the path every customer wants to take,<br />

regardless of the type of loss or its severity. It should be<br />

digital by choice and not digital by force.<br />

Q<br />

A<br />

As policyholders and brokers increasingly seek<br />

digital self-service options, when interacting<br />

with an insurance company, what are some of<br />

the more novel technologies you are seeing<br />

come to market?<br />

I stand in great company when it comes to<br />

being excited about the potential of generative<br />

AI. There are still risks to understand and<br />

mitigate when it comes to security, bias, and data<br />

quality, but there is no time to wait. We must jump<br />

in and begin to experiment with framing a scalable<br />

process for execution and governance. The ‘crawl-walkrun’<br />

approach of some carriers is to begin with their<br />

internal knowledge bases of product brochures, service<br />

procedures, and even technical support scripts to stand<br />

up a Large Language Model. When put in the hands of<br />

customer service representatives, this speeds up their<br />

ability to respond to questions and solve problems. It<br />

can also reduce employee downtime and internal help<br />

desk calls.<br />

Some other technologies that excite me might not be<br />

considered novel, per se; rather, it’s how more familiar<br />

solutions are being utilized to solve real, long-term<br />

customer experience problems. In addition, this often<br />

addresses sizeable drivers of operational expense.<br />

I previously observed that customers want ease,<br />

options, transparency, and proactive experiences,<br />

which include agents and brokers, too. For me, that<br />

sums up the ‘Amazon effect’ on expectations. However,<br />

for digital self-service expectations to at least be met<br />

(if not exceeded), there cannot be a digital approach<br />

on the front-end only. The customer of today is savvy<br />

enough to recognize when the service experience is not<br />

fully automated, and the expense pressures across the<br />

insurance industry are real and only increasing.<br />

Conversational AI solutions are enabling carriers to<br />

offer a consistent brand experience, regardless of the<br />

line of business and/or journey where the agent, broker,<br />

or policyholder is engaging. These solutions enable<br />

carriers to automate the handling of high-volume and<br />

predictable service requests. They also give carriers the<br />

tools to eliminate some drivers for customers, brokers,<br />

<strong>62</strong> | MODERN INSURANCE


INSURTECH<br />

and agents to reach in, by automating proactive status<br />

updates. The best question is the one that is answered<br />

before it’s asked – from the perspective of both<br />

experience and expense.<br />

There is an increasing array of data from reliable<br />

third parties being pulled in, reducing the amount of<br />

information that agents, brokers, and policyholders<br />

must share (not to mention locate) in order to obtain<br />

a quote or change a policy. These solutions are a<br />

win-win because they also improve the quality of the<br />

information, for faster and more precise underwriting as<br />

well as profitable pricing.<br />

Technology is enabling carriers to provide their<br />

customers with real-time loss prevention guidance<br />

specific to their homes or buildings. Or, as I noted<br />

earlier, alerting workers via a wearable device that<br />

their lifting technique puts them at risk of sustaining<br />

an injury. In property, proactive alerts about roof wear<br />

or damage detected by satellite imagery, drones, or<br />

infrared cameras can avert the customer experiencing<br />

a loss.<br />

Documents as a means of sharing data between nonintegrated<br />

stakeholders are not going away. What’s<br />

changed are the expectations on how fast they will be<br />

processed. From fleet lists generating a commercial<br />

auto quote to bulk provider network billings, time is<br />

of the essence to recognize those files, and get the<br />

information they contain to a policy, claim, or payment<br />

system. AI-based intelligent document processing (IDP)<br />

solutions automate the detection, extraction, validation,<br />

and interfacing of this key data. Taking people out of<br />

this process enables straight-through processing of the<br />

underwriting referral, accelerating responsiveness to the<br />

broker, agent, or customer.<br />

What steps can insurance companies take<br />

to ensure that consumers have access to<br />

Qappropriate coverage, and are protected against<br />

unfair and deceptive practices?<br />

The more information carriers have about a risk,<br />

the more precise they can be in offering the best-<br />

products, services, and coverage limits. Earlier,<br />

Afit<br />

I mentioned the increased sourcing of third-party data<br />

as something that excites me. It speeds up service and<br />

eliminates any disconnect between what the customer<br />

needs to be covered, and the coverage provided.<br />

<strong>Insurance</strong> companies are wholly invested in doing<br />

right by their customers. Carriers in the U.S. operate<br />

within a robust, state-based regulatory system that<br />

provides important checks and balances on product<br />

scope, rates, and licensing - in addition to solvency.<br />

<strong>Insurance</strong> regulation strives to reinforce public<br />

confidence by managing the big-picture view for fair<br />

pricing, transparency, and availability across competing<br />

companies.<br />

Q<br />

In your opinion, what are some of the challenges<br />

that insurance companies face in fulfilling their<br />

Consumer Duty?<br />

<strong>Insurance</strong> is an array of financial protection<br />

solutions that exist within an increasingly<br />

A complex and ever-changing world. The industry<br />

is not simple, and it can therefore be difficult for<br />

consumers to trust and understand. The commercials<br />

that show claims adjusters as evil conspirators seeking<br />

to deny claims whenever possible only heighten that<br />

mistrust.<br />

<strong>Insurance</strong> in many instances is a mandatory consumer<br />

purchase, driven by state regulation or contract.<br />

Almost forty years into my own industry journey, I’ve<br />

yet to meet someone who was excited to purchase a<br />

policy, myself included! Even unconsciously, insurance<br />

purchases are a reluctant consumer buyer journey at<br />

best. Do I rest much easier knowing that my family and<br />

I are protected? Absolutely! But do I celebrate when<br />

my monthly premium auto-pay notification arrives?<br />

Definitely not!<br />

Q<br />

Any personal anecdotes to share as a consumer<br />

in terms of what insurers are doing right, and<br />

what needs to change?<br />

I am in awe of the insurance industry’s<br />

unwavering focus to continuously innovate both<br />

A its products and processes, to never fall short of<br />

fulfilling its purpose. At the same time, everything is<br />

shifting - from risks and climate, to the economy and<br />

the consumer they are striving to serve.<br />

As I reflect on how you framed Consumer Duty in your<br />

introductory message, I am struck by the key part that<br />

experience plays. For example, a consumer can have<br />

two different perceptions when learning about the<br />

total loss payout for their car, in terms of it being ‘fair<br />

and reasonable’. Closing the gap between intent and<br />

perception requires an outside-in voice, in terms of both<br />

tone and terminology.<br />

I’m borrowing from the playbooks of carriers that I<br />

have worked for or with. Have someone other than<br />

an insurance professional periodically test-drive your<br />

company’s consumer interactions. Tapping into the<br />

expectations of my son (Gen Z), husband (chef), and<br />

mother (senior) has caused me to see and hear things<br />

differently.<br />

As carriers continue to innovate, I hope they will double<br />

down on agility to move the needle as quickly as<br />

possible, transforming in discreet increments. The faster<br />

we can deliver focused changes, the sooner we can<br />

hear the voice of the customer telling us if we’re on the<br />

right path.<br />

Meredith Barnes-Cook,<br />

Partner, ReSource Pro Consulting<br />

MODERN INSURANCE | 63


INSURTECH<br />

JobsOhio<br />

QRon, it was wonderful to see you and JobsOhio this<br />

past June at Insurtech Insights! You have done a<br />

phenomenal job growing JobsOhio into a global<br />

insurtech and fintech hub, and you can certainly speak to<br />

Consumer Duty in insurance from a few different angles.<br />

I’m keen to hear how you’ve seen the role of technology<br />

impact the customer’s expectations in recent years?<br />

AI’ve said many times that the customer is in the<br />

driver’s seat right now. The policyholder of the<br />

past would call or visit their agent, provide various<br />

pieces of information, get grouped together with a similar<br />

population, and pay a premium based on similar risk<br />

categories. Not exactly a truly personal experience!<br />

The insurance industry is getting better at using data,<br />

AI, and ML to assess risk more accurately and more<br />

personally. Additionally, customers can control the<br />

experience – insurance companies need to meet them when<br />

and where they want to be met.<br />

QHow has technology enhanced the customer’s<br />

journey in the claims process? What are some<br />

obstacles to overcome in the claims process as it<br />

relates to Consumer Duty?<br />

AWith the claims process, there are two key factors.<br />

Firstly, it’s a moment of truth for both parties, and<br />

secondly, service is being judged on the speediness<br />

and accuracy of the claim. No customer buys insurance<br />

wanting to file a claim because their valuable property is<br />

affected. In the event that a loss occurs, the policyholder<br />

expects to be indemnified with little interruption in their<br />

life. If the insurance company creates a memorable<br />

experience, good or bad, the policyholder will have a<br />

reaction to that service. The positive reaction is that the<br />

customer is retained and will voice their pleasure within<br />

their circle of friends and family. On the contrary, if they are<br />

negatively impacted, the company will lose a policyholder<br />

to a competitor. Either reaction may result in not only one<br />

policy lost, but multiple – all due to the customer’s influence.<br />

QAs policyholders and brokers increasingly seek<br />

digital self-service options, when interacting with an<br />

insurance company, what are some of the more novel<br />

technologies you’re seeing come to market?<br />

ALots of eyes go right to P&C, since those are the<br />

most prominent. However, I love technologies<br />

that aggregate quotation in the small business<br />

space. Commercial insurance is a huge relationship side of<br />

the business, and it requires a ton of trust. Let the broker/<br />

agent do what they do best and make relationships to sell<br />

business. If the agent spends hours, days, or even weeks<br />

creating a relationship, the last thing they want to hear<br />

is that their prices aren’t competitive. Most agents aren’t<br />

independent anymore, and being able to get the right<br />

quote for the right price allows them to capitalize on what<br />

they do best.<br />

QWhat steps can insurance companies take to ensure<br />

that consumers have access to appropriate coverage<br />

and are protected against unfair and deceptive<br />

practices?<br />

AWhile customer experience is one of the more<br />

forward facing and noticeable innovations, accurately<br />

assessing and covering risk is going to impact an<br />

insurance company’s bottom line. Transparency on the front<br />

end is important because it earns trust. Customers are super<br />

sensitive to price, and if an agent is doing sneaky things to<br />

earn the business based on price, it may backfire during that<br />

aforementioned moment of truth.<br />

On the flip side, transparency is important to the insurance<br />

company because it may help to mitigate fraud. There are<br />

new technologies that improve upon initial risk assessment,<br />

and those get my attention too.<br />

QIn your opinion, what are some of the challenges<br />

that insurance companies face in fulfilling their<br />

Consumer Duty?<br />

A<br />

<strong>Insurance</strong> is a super competitive industry. Because<br />

insurance used to be administratively onerous to the<br />

customer, it was more of a pain to find an alternative<br />

to their current insurer. The result was a policyholder<br />

being unhappy, but just dealing with the lack of service.<br />

Nowadays, it’s a lot easier to test the market, and customers<br />

are changing insurers for less<br />

money than ever. That means<br />

insurers need to bring their<br />

A-game, because the customer<br />

always has the upper hand. ‘If<br />

you aren’t growing, you’re<br />

dying’ is an old saying - but in<br />

the insurance industry, I believe<br />

it’s less about growing and<br />

more about innovating.<br />

Ron Rock,<br />

Managing Director - Financial<br />

Services, JobsOhio<br />

64 | MODERN INSURANCE


INSURTECH<br />

EDITORIAL<br />

BOARD<br />

WELCOME to the Insur.Tech.Talk<br />

Editorial Board.<br />

<strong>Modern</strong> <strong>Insurance</strong> <strong>Magazine</strong> is delighted to bring our board of insurtech experts together<br />

in a showcase of thought leadership insights from the very heart of the sector. In this issue,<br />

we’re looking at how technology can aid insurers, brokers and MGAs in their attempts to stay<br />

compliant with the new Consumer Duty…<br />

This issue voices the thoughts of...<br />

Scott Holmes,<br />

Sales Director UK&I,<br />

Quantee<br />

Nelius Strydom,<br />

Chief Product Officer,<br />

Contemi Solutions<br />

William Pitt,<br />

Head of Customer Service,<br />

Contemi Solutions<br />

Denise Garth,<br />

Chief Strategy Officer,<br />

Majesco<br />

André Symes,<br />

Group CEO,<br />

Genasys Technolgies<br />

Tim Hardcastle,<br />

CEO and Co-Founder,<br />

INSTANDA<br />

MODERN INSURANCE | 65


INSURTECH<br />

Emphasising the<br />

Policyholder’s Duty<br />

The UK insurance industry is a robust and highly regulated<br />

sector, one that plays a critical role in safeguarding individuals<br />

and businesses from financial risks. While insurers have a<br />

duty to provide reliable coverage and handle claims fairly,<br />

consumers also have an essential role to play in this dynamic<br />

relationship. This article emphasises the responsibilities and<br />

actions that policyholders should take to ensure a fair and<br />

efficient experience.<br />

Scott Holmes,<br />

Sales Director UK&I, Quantee<br />

Individuals and businesses have responsibilities and<br />

obligations when purchasing and maintaining insurance<br />

policies. In the context of the UK insurance industry,<br />

Consumer Duty is guided by several key principles:<br />

n Honesty and Disclosure<br />

n Research and Comparison<br />

n Understanding the Policy<br />

n Prompt Payment of Premiums<br />

n Reporting Claims<br />

n Preventing Fraud<br />

n Seeking Redress<br />

Consumers must provide accurate and complete<br />

information. It’s crucial to update their insurer about any<br />

changes in circumstances during the policy term to ensure<br />

that coverage remains appropriate and valid. It’s a common<br />

scenario that claims are not paid because the policy no<br />

longer accurately reflects the risk, with the consumer<br />

ultimately losing out as a result.<br />

Consumers also need to be actively researching and<br />

comparing insurance policies to find the one that best suits<br />

their needs. In turn, insurance companies must make this<br />

a simple, understandable and easy process. Price should<br />

not be the sole deciding factor - and so if consumers<br />

understand the product they are buying, the risk of underinsurance<br />

should be mitigated.<br />

The claims journey can often be a testing experience<br />

for consumers. This is a stressful period which is often<br />

associated to a loss, and if the claims process is not a<br />

straightforward one then this can lead to poor experiences<br />

where the consumer loses trust. The consumer needs to<br />

report these losses promptly so the insurer can deal with<br />

the claim using accurate information, and compensate<br />

the consumer swiftly. This relationship needs to be<br />

incentivised in order to enhance communication and<br />

streamline the process, one where the consumer does not<br />

delay their initial action and postpone a positive outcome.<br />

Fraud remains a significant cost to insurers, which is then<br />

passed on to consumers through increased premiums.<br />

This vicious cycle has to be broken. For the vast majority<br />

of consumers, fraud is not on the agenda. However,<br />

opportunistic fraud does occasionally occur, alongside<br />

subtle changes to risk information in an attempt to obtain<br />

a lower price. This ultimately leads to insurers mitigating<br />

fraud through higher premiums, but there is scope for a<br />

real solution to this is in Big Data.<br />

Using the various data sources that now exist for the<br />

majority of retail or consumer-based products, there is a<br />

reduced need for self-declared information. In theory, this<br />

should result in more accurate pricing; consumers need<br />

to understand this and provide the consent for their data<br />

to be used. As a consequence, this should help to reduce<br />

inflated premiums over time.<br />

Consumer Duty is a vital component of the UK<br />

insurance industry, fostering trust and accountability<br />

between insurers and policyholders. By fulfilling their<br />

responsibilities honestly and diligently, consumers can<br />

help to maintain the integrity of the insurance market and<br />

ensure that their insurance needs are met effectively.<br />

Moreover, understanding their rights and the new<br />

regulatory framework in place can empower consumers<br />

to seek redress if they encounter unfair treatment. In this<br />

symbiotic relationship between consumers and insurers,<br />

transparency, honesty, and cooperation are key to a<br />

successful and reliable insurance experience.<br />

MODERN INSURANCE | 67


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INSURTECH<br />

Empowering<br />

Consumers:<br />

New Duty Regulations,<br />

the Impact on the<br />

<strong>Insurance</strong> Industry, and<br />

the Tech Revolution<br />

Nelius Strydom,<br />

Chief Product Officer, Contemi Solutions<br />

In today’s digital age, consumers wield unprecedented power<br />

and influence, often driving market changes through their<br />

choices and demands. Recognising this, governments and<br />

regulatory bodies are increasingly enacting new Consumer<br />

William Pitt,<br />

Duty regulations to protect and empower individuals. Head of Customer Service, Contemi Solutions<br />

Consumer Duty regulations encompass<br />

a broad range of laws and standards<br />

aimed at safeguarding the rights and<br />

interests of consumers in various<br />

industries.<br />

What does it mean for the financial<br />

industry? The Financial Conduct<br />

Authority (FCA) states that financial<br />

firms must act in good faith towards<br />

customers and avoid causing them<br />

foreseeable harm, enabling and<br />

supporting them to pursue their<br />

financial objectives.<br />

These regulations are evolving to<br />

address contemporary challenges in<br />

areas such as data privacy, product<br />

safety, and ethical business practices.<br />

In effect, the Consumer Duty<br />

regulation should offer customers the<br />

support they need when they need it,<br />

and in a form of communication that<br />

they understand. Products and services<br />

should also meet their needs and offer<br />

fair value, while protecting consumer<br />

privacy at the same time.<br />

Let’s explore some of the aspects that<br />

are key to this regulation for financial<br />

institutions.<br />

Data Privacy and Security<br />

Technology has brought about an<br />

explosion of data, and with it, concerns<br />

about privacy and security. Advanced<br />

encryption techniques, tokenisation,<br />

consent management and data<br />

anonymisation are all key technologies<br />

that help companies to comply<br />

with data privacy regulations while<br />

maintaining efficient operations.<br />

Product Transparency & Services<br />

Consumers have become increasingly<br />

conscious and require full<br />

transparency about the products<br />

they are purchasing. Regulations in<br />

this area are aimed at ensuring that<br />

the products on offer help customers<br />

to achieve their financial goals,<br />

promoting access to clear and truthful<br />

information.<br />

<strong>Insurance</strong> software solutions like<br />

Contemi’s Seamless.Insure provide<br />

flexibility and transparency in<br />

insurance products, as well as a selfservice<br />

portal to insurance customers<br />

– one that offers direct access to all<br />

relevant information. This can allow<br />

consumers to make an informed<br />

purchase decision, or provide<br />

clarification around what is included<br />

in their policy. Customers are also able<br />

to set reminders for themselves, or<br />

register a claim via this platform.<br />

Enhancing Consumer Engagement<br />

Technology is facilitating direct<br />

and meaningful engagement<br />

between consumers and insurance<br />

providers. Holistic access to<br />

relevant customer data allows for<br />

a positive, efficient experience in<br />

customer service. Furthermore,<br />

advancements in technology - like<br />

chatbots for customer service, and<br />

personalised marketing powered by<br />

AI - can contribute to more efficient<br />

consumer-business interactions.<br />

Thus, technology is not just a<br />

supporting actor; it’s a catalyst for<br />

change, enabling the enforcement<br />

of regulations and empowering<br />

consumers with greater transparency,<br />

control, and protection. Technology<br />

will also help companies to ensure<br />

and measure the value they deliver to<br />

their customers at every stage of the<br />

lifecycle.<br />

Technology can:<br />

• Guarantee the availability of clear<br />

and easy to understand information<br />

to prospective customers during the<br />

sales stage, through interactive and<br />

intuitive platforms available across all<br />

devices.<br />

• Provide instant response to queries<br />

eg. through AI driven live chats.<br />

• Make data collection easy through<br />

quick onboarding dashboards,<br />

reducing the need to enter repetitive<br />

data.<br />

• Use comprehensive data collection<br />

and analysis systems, along with<br />

robust risk assessment systems, all of<br />

which can quickly help underwriters<br />

to evaluate profiles and offer the<br />

right solution based on the specific<br />

needs of the consumer.<br />

• Set up premium reminders.<br />

• Easily access all information available<br />

to the consumers, evaluating their<br />

policies and understanding the<br />

depth of their coverage.<br />

• Offer an intuitive claims system for<br />

customer support when they need it<br />

most.<br />

As we navigate this ever-changing<br />

landscape, the collaboration between<br />

governments, insurance businesses and<br />

technology innovators will be vital in<br />

achieving Consumer Duty objectives.<br />

MODERN INSURANCE | 69


INSURTECH<br />

Customer First<br />

– It’s a Real Thing<br />

The future is all about the customer. Customer-first strategies<br />

can provide long-term growth, so customer signals must shape<br />

business strategies. What signals are we seeing today? From COVID<br />

to historic inflation, severe weather events and the rising cost of<br />

insurance, customers are enduring an ongoing string of challenges<br />

that have shaken their sense of financial security in how they can<br />

protect their homes, cars, life, physical and financial well-being.<br />

Denise Garth,<br />

Chief Strategy Officer, Majesco<br />

While insurance’s traditional products have and will always<br />

be pivotal in creating peace of mind for the customer, new<br />

and expanding risks, customer behaviours and expectations<br />

require new ideas and approaches. Today’s customer judges<br />

the insurance experience on an entirely different scale.<br />

The rise of individualisation and personalisation is rewriting<br />

the customer experience and the insurance process - from<br />

the products offered and their pricing and underwriting, to<br />

the channels recommended and the value-added services<br />

provided. Customers are seeking simple, humanised<br />

experiences that require a shift from a product-centric<br />

approach to a customer-centric one.<br />

Today’s customers are living different lifestyles and possess<br />

far greater digital proficiency than ever. They demand<br />

different experiences and have different expectations about<br />

value. They want a risk product, value-added services, and<br />

an experience that provides them with what they need to<br />

manage their lives. Plus, they need financial wellness that<br />

humanises the entire customer lifecycle.<br />

But for many customers, there is a gap between what they<br />

expect, want, and need, versus what insurers are delivering.<br />

This gap influences long-term customer growth, value, and<br />

loyalty. It demands a customer-centric strategy.<br />

The customer expectation gap is most prevalent with<br />

Millennials and Gen Z, who are not satisfied with traditional<br />

insurance products, processes and business models. This was<br />

demonstrated in Majesco’s consumer and SMB research. As<br />

digital natives, they expect and demand digital capabilities<br />

and products that will align to their activities and behaviours,<br />

personalised to them. Even the older generations are<br />

becoming digitally-savvy, and they have similar expectations<br />

for service!<br />

The implication is that traditional product-oriented strategies<br />

developed from an inside perspective handicap insurers.<br />

Savvy, innovative companies are redefining insurance from<br />

an outside-in perspective, adapting to what customers<br />

want and expect despite their generational demographic.<br />

They are methodically peeling away generations of insideout<br />

perspectives and operations that require customers to<br />

conform to the way insurance works. Their innovative teams<br />

are transforming insurance from a mysterious, confusing,<br />

and difficult ordeal most would rather avoid, to a more<br />

transparent, simple, and engaging experience.<br />

How are insurers humanising insurance? They are offering<br />

niche, personalised products, services, and experiences that<br />

align with a customer’s specific risk needs. They do this by<br />

using unique risk, lifestyle, and behaviour data.<br />

Customer-first products also support the rising demand for<br />

financial wellness. Since insurance is a vital tool for protecting<br />

the financial security of individuals and businesses, additional<br />

services that enhance this protection should be a good fit for<br />

insurers to offer to customers, regardless of the specific lines<br />

of business they offer.<br />

Companies that offer and integrate their products and<br />

value-added services into this financial wellness approach<br />

can put themselves in a strong position and gain loyalty.<br />

More importantly, these companies can gain a competitive<br />

advantage over those that place their products and services<br />

as a single or siloed item, instead of a vital piece of a much<br />

broader financial wellness puzzle.<br />

The advent of Consumer Duty embraces the customercentric<br />

approach. It encourages insurers to showcase<br />

their products in terms of value to the customer, helping<br />

customers to achieve financial wellness and understanding to<br />

the overall benefit of everyone.<br />

There is no turning back. The future is here.<br />

Game on!<br />

MODERN INSURANCE | 71


INSURTECH<br />

André Symes,<br />

Group CEO, Genasys Technologies<br />

Consumer<br />

Focus:<br />

Realising Commercial<br />

Ambition and<br />

Delivering Customer<br />

Satisfaction<br />

It’s a tough external environment for the insurance industry right<br />

now. High inflation is impacting claims costs, and the rising cost<br />

of living is affecting consumer behaviour. In addition to these<br />

economic headwinds, regulatory standards through the new<br />

Consumer Duty mean that insurance businesses have paused to<br />

reflect on their product offering and interactions with customers,<br />

with any required operational changes carrying a financial cost.<br />

Particularly where the industry is working with inflexible legacy<br />

technology, these changes have probably been felt quite acutely.<br />

Keeping policyholders satisfied and making sure that<br />

your COR meets shareholder expectation is a balancing<br />

act. But how do you achieve this?<br />

Building in adaptability<br />

In my experience, the head start goes to insurance<br />

leaders who are embracing what we at Genasys call a<br />

‘pro-adaptive’ ethos.<br />

A focus on implementing an API-first core tech<br />

platform lies at the core of pro-actively building<br />

adaptability into the DNA of an organisation. This<br />

gives the digital capability and flexibility to lean into<br />

future regulatory change and react rapidly to changing<br />

market conditions, particularly in areas of the industry<br />

where we can expect further changes and reform.<br />

As a result, pro-adaptive insurance businesses<br />

don’t have to pause expensive, five-year digital<br />

‘transformation’ programmes. Instead, they pivot these<br />

once ring-fenced resources in order to adapt to the<br />

shifting environment.<br />

Plugging in to innovation<br />

The commercial advantage lies with insurers, carriers<br />

and MGAs that are making the transition to an API-first<br />

core platform. Why? Because they have the ability to<br />

plug into tech innovation and multiple data sources, as<br />

well as automating workflows. All of this is designed to<br />

suit and protect their commercial needs today, while<br />

realising their vision for the future.<br />

Let’s take fraud detection as an example. By being<br />

able to plug into multi-bureau data sets, you get an<br />

exponential increase in the accuracy of detecting<br />

possible fraud at first notification of loss (FNOL), which<br />

helps to protect your balance sheet. The consumer<br />

benefits, too. This wealth of data provides reliable rules<br />

to support speedy, accurate, automatic claims payments<br />

for legitimate claims – all of which enhances customer<br />

loyalty.<br />

The impact of core tech on COR<br />

The results speak for themselves when you start to see<br />

how a tech stack, built around a single core platform<br />

which everything can connect to and evolve as<br />

necessary, significantly improves the policy and claims<br />

administration processes for the insurer and the insured.<br />

At Genasys we’re working with one client where the use<br />

of our tech to drive innovative, automated workflows is<br />

reducing the average claim time – from first notification<br />

to accurate settlement – from two days to just five<br />

minutes. It’s a win-win.<br />

An API-first approach helps to drive measurable<br />

operational efficiencies, supporting action to bring down<br />

the COR while delivering a better customer experience<br />

at the same time.<br />

Preparing for the future customer<br />

Let’s remember that the digital native, Gen Z customer<br />

will become the future consumer powerhouse. Growing<br />

up in an on-demand, online world has shaped how<br />

they want to interact with companies – with very clear<br />

expectations of how they want to be treated.<br />

Now is the time to adapt if insurance businesses are<br />

to remain relevant to their customer base and survive.<br />

Tech partners who can help their clients realise their<br />

technological ambition are playing an integral role<br />

in supporting the ethos of Consumer Duty: helping<br />

to positively change the way in which the consumer<br />

experiences insurance.<br />

MODERN INSURANCE | 73


INSURTECH<br />

Consumer Duty:<br />

How Technology<br />

Helps Compliance<br />

It’s official: the Financial Conduct Authority (FCA) has<br />

now announced the rollout of its new Consumer Duty<br />

regulations from 31st July 2023. This is perhaps the most<br />

significant change to insurance industry regulations for<br />

over 20 years.<br />

Tim Hardcastle,<br />

CEO and Co-Founder at INSTANDA<br />

It’s clear that these changes will<br />

have a seismic impact on insurance<br />

professionals, stakeholders, and<br />

customers. With that in mind, what can<br />

the enterprises within the insurance<br />

industry do to ensure they can adapt<br />

to new regulatory changes, anticipate<br />

further reform down the line, and put<br />

consumers first without affecting<br />

revenue targets?<br />

This article will discuss how insurers<br />

can prepare themselves for compliance<br />

issues, why being proactive is the best<br />

course of action, and how no-code<br />

technology and core platforms can help<br />

insurers to future-proof their businesses.<br />

The Implications of the new<br />

Consumer Duty<br />

What does the new Consumer Duty<br />

mean for all of us? In brief, these<br />

regulations are designed to ensure that<br />

insurance products are fit for purpose<br />

throughout the customer lifecycle.<br />

Insurers now have to work harder<br />

to understand their customers. To<br />

comply with the new regulations, they<br />

must continually assess whether their<br />

products provide value for money and<br />

remain suitable for customers. If not,<br />

they’ll need to carry out more product<br />

testing in order to remain aligned with<br />

changing demands.<br />

The FCA estimates that implementation<br />

costs to the industry could be as high<br />

as £2.4bn. <strong>Insurance</strong> firms need to<br />

assess governance, revise their customer<br />

service, and develop new systems<br />

and processes. Continually reviewing<br />

product suitability means that insurance<br />

carriers must maintain ongoing<br />

communications with customers at all<br />

stages of the customer lifecycle; from<br />

quote and apply, to inception, renewal,<br />

cancellation, or claim.<br />

Furthermore, insurers will also be forced<br />

to create and release more products<br />

than ever before to ensure that every<br />

possible and potential customer need<br />

is catered for. This rapid acceleration<br />

of the time-to-market is obviously<br />

a clear concern for insurance firms,<br />

particularly those who are reliant on slow<br />

or outdated infrastructures and admin<br />

systems.<br />

The value of new tech<br />

The impact of new regulatory<br />

requirements like this one perfectly<br />

emphasises the reason why technology<br />

has a vital role to play in helping insurers<br />

and MGAs to stay compliant.<br />

The ability of businesses to meet and<br />

exceed these expectations is fully<br />

dependent upon the platforms they have<br />

access to. Clearly, insurers cannot rely<br />

on legacy technology if they want to<br />

release more products at a faster rate,<br />

whilst enabling open dialogue with their<br />

customers to drive ongoing business<br />

decisions. By using digital solutions<br />

to build Minimal Viable Products<br />

(MVPs), insurers will cut their product<br />

development time from many, many<br />

months to just a matter of weeks.<br />

However, implementing the modern<br />

technology needed to achieve these<br />

results can prove to be a costly,<br />

challenging, and time-consuming<br />

process. Insurers may not have the<br />

resources and expertise to code the<br />

platform they need to remain compliant.<br />

Additionally, outsourcing to a thirdparty<br />

has its own pitfalls, as these<br />

programmers are far too removed from<br />

customer needs to fully understand the<br />

intricacies of the insurance industry.<br />

Fortunately, there’s another way - one<br />

that grants insurers full control over the<br />

development and implementation of<br />

their tech. This also allows them to build<br />

and integrate what they want, how they<br />

want it, without writing a single line of<br />

code.<br />

How no-code digital platforms<br />

can help you prepare<br />

No-code solutions enable insurers to<br />

build, test, and launch new products<br />

quickly, while minimising the cost and<br />

resources needed. These solutions are<br />

designed to be simple and intuitive<br />

to use, meaning that insurers can<br />

use core digital systems to design<br />

products quickly, test them out<br />

in the marketplace, and store all<br />

documentation in different portals -<br />

all without fussing over the technical<br />

details.<br />

Plus, in line with the requirement<br />

for increased communication with<br />

customers, insurance firms can<br />

configure which predefined questions<br />

they want to ask consumers in the<br />

customer portal. The newly integrated<br />

platforms can even be used as a<br />

communication channel to gather<br />

customer feedback.<br />

Finally, no-code solutions should be<br />

able to flag when vulnerable customers<br />

are identified, helping insurers to<br />

understand whether they should be<br />

purchasing particular products.<br />

Why you need to act now<br />

The FCA isn’t specifically telling<br />

businesses how to put its new rules into<br />

effect, and this is a key takeaway. It’s<br />

imperative that insurers and MGAs take<br />

the initiative and act now. By acting<br />

early and demonstrating due diligence,<br />

carriers have a much higher chance of<br />

avoiding noncompliance penalties.<br />

Plus, as we’ve discussed, taking steps<br />

to adopt modern technology will<br />

help insurers to get ahead of their<br />

competitors and level up their platform<br />

capabilities. By acting early, they can<br />

offer a larger number of better-quality<br />

products, and release them faster<br />

than ever.<br />

These new regulations don’t have to be<br />

a cause for concern. Instead, see this as<br />

your time to embrace the possibilities<br />

of no-code platforms, alongside a<br />

further key opportunity for business<br />

development.<br />

74 | MODERN INSURANCE

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