In the course of our regular dealings with our general insurance firms, we see many examples of clear communication efforts to consumers at renewal time. However, we would encourage any firm to familiarise itself with the consultation paper content and measure its existing approach to renewals against the proposed rules and guidance. A number of key measures should be considered:

• Are client communications at renewal clear, fair and not misleading?
• Do clients genuinely engage in the renewal process and make better informed decisions?
• Does the customer’s cover remain good value?
• Does the customer’s cover continue to represent good value?
• Do you, the broker, have a defined renewal process including guidance as to when and how often a policy is re-brokered or compared to the market?

Remember, most general insurance contracts are annually renewable; therefore, the same ICOBS rules apply for every renewed policy because it is effectively a new contract (establishing demands and needs, D&N statement, etc).

As the regulator is aiming to have any new rules and guidance in place by January 2017, it would be sensible for general insurance firms to include any such exercise within their compliance monitoring programme for this year. Also, be aware that insurers are likely to be taking actions in response to the consultation paper.

As with many of the FCA’s consultations, there is an opportunity for firms to explicitly demonstrate their commitment to Treating Customers Fairly and to be seen to deliver the standards and outcomes expected by the regulator.

ATEB clients should speak with their account manager as necessary; otherwise contact ATEB here to find out how we can help.