Insurance2day Insurance Services Ltd – Mid Term Adjustments – Consumers
If there have been any changes to the firm’s TOBA (Status Disclosure: General) the firm must advise the customer of the same prior to conclusion of the Mid-Term adjustment.
If the Mid-Term-Adjustment results in a different scope of service being offered to the consumer [e.g. the consumer moves to a ‘high net worth’ property and for this type of insurance the firm only uses a single insurer] the consumer must be advised of the revised scope of service being offered by I2D. This information must be provided to the consumer in writing prior to conclusion of the Mid Term Adjustment.
If the Mid-Term-Adjustment results in the policy being remarketed / replaced our Consumer New Business Procedures should be followed to ensure the consumer is provided with all the required ICOBS Disclosure Information.
I2D must, at all times act in accordance with the Customer’s Best Interests Rule and pay due regard to the interests of its customers and treat them fairly.
I2D must take reasonable steps to ensure that the consumer is given appropriate information about the mid-term adjustment in a comprehensible format so that the consumer can make an informed purchasing decision. The level of information required will vary dependent on:-
The knowledge, experience and ability of a typical consumer for the policy
The policy terms including main benefits, exclusions, limitations, conditions and its duration
Overall complexity of the policy
Whether the policy is bought in connection with other goods or services
Distance communication requirements
Whether the same information has been provided to consumers previously and if so when.
To ensure the consumer is provided with appropriate information I2D should advise the consumer of:-
a) Changes to the premium, unless the change conforms to a previously disclosed formula;
b) Details of the amount of any fees. Where an actual fee cannot be given I2D must give the basis for calculating any fees, enabling the consumer to verify them. This information must be given to the consumer before the consumer incurs liability to pay the fee or before conclusion of the amendment, whichever is earlier.
c) Changes to any term or condition of the Policy, together with an explanation of any implications (including any changes to the benefits and/or significant and unusual exclusions) of the change where necessary; and
d) Any changes in the way the Insurer operates or any changes in the manner that the Insurer handles the insurance which may affect the consumer.
e) If an Insurer changes the premium or any term or condition of a Policy then I2D must write to the consumer detailing the changes, in good time before the change takes effect. If the change in premium affects the instalments being collected the consumer must be advised prior to the change in instalments occurring.
f) If the change is at the request of a consumer, and it is impracticable to write to the consumer before the change takes effect, then I2D ’s representative must:
Explain the implications of the change to the consumer before the change takes effect; and
Write to the Consumer with full details promptly after the change takes effect.
Following the Mid-Term Adjustment, we must request the appropriate endorsement from insurers and diary for seven days.
Endorsements must be checked and issued promptly to the consumer. Any change in premium must be checked against that debited to the consumer.
Internal documents must be updated to reflect the change in cover.