Insurance2day Insurance Services Ltd – Renewal Procedures – Commercial Clients
These procedures are to be followed for Insurance2day Insurance Services Ltd (I2D) commercial client renewals, however different rules may apply to policies with a duration of a month or less that renew automatically.
Prior to Renewal
- At all times the I2D representative must act in accordance with the Customer’s Best Interests rule and pay due regard to the interests of its customers and treat them fairly.
- The I2D representative must, in good time before expiry of the policy, liaise with the client to discuss the renewal, update any fact find held by the firm, revisit the client’s demands and needs and discuss the scope of service to be provided at renewal.
- The I2D representative must check whether any previously purchased Optional Additional Products have been sold on an Opt In basis and that the client fully understands the cost of the optional additional cover, the scope of the cover and that the product is optional. If this is not the case, the Optional Additional Product must be sold on an opt in basis at renewal.
- The I2D representative is to remind the customer of the importance of a thorough information gathering exercise and the duty of fair presentation including the requirement to disclose every material circumstance which the insured knows or ought to know.
- Where the insured is unable to make a fair presentation of the risk to be insured it is the duty of I2D to advise insurers that further enquiries will be required to underwrite the risk accurately.
- Timeframes must be set for I2D to report to the customer with the results of any re-broking exercise and subsequent recommendations.
- The I2D representative must, in good time before the expiry of the policy, provide the customer with renewal terms in a comprehensible format so that the customer can make an informed purchasing decision.
- If the policy is not to be renewed, the I2D representative should notify the customer in good time in order that the customer can make alternative arrangements.
- If the policy is re-broked and an alternative insurer recommended the firm’s new business procedures for commercial customers should be followed to ensure that the client is issued with all the required ICOBS Disclosure Information.
- The timing of any re-broking presentation to insurers must be such that it enables underwriters sufficient time to fully consider the information provided and make further enquiries where necessary to reveal undisclosed material circumstances.
- The level of information required will vary dependent on:
i) The knowledge, experience and ability of a typical customer for the policy
ii) The policy terms including main benefits, exclusions, limitations, conditions and its duration
iii) Overall complexity of the policy
iv) Whether the policy is bought in connection with other goods or services
v) Distance communication requirements
vi) Whether the same information has been provided to customers previously and if so when.
- If there have been any changes to the firm’s Terms of Business document (Status Disclosure: General) the I2D representative should ensure that the customer is provided with a link to the up to date Terms of Business document. If there have been no changes to the Terms of Business Document there is no requirement to issue the same however, the I2D representative must be able to demonstrate that the customer has received a copy of the current Terms of Business Document within the last 12 months and for the sake of good practice must confirm to the customer that the previously issued Terms of Business Document continues to apply
- The customer must be given a statement of their demands and needs based on information gathered from them. The statement of demands and needs must be tailored to the individual client and should include reference to the underlying reasons for any advice / recommendation made.
- If the renewal is a non-advised sale the customer must still be issued with a demands and needs statement tailored to reflect this type of sale and there must still be a matching of the clients demands and needs to the proposed policy.
- If different from the basis on which the insurance was incepted, the I2D representative must describe the basis upon which renewal is offered, for example:
– A fair analysis of the market;
– A limited number of insurers (list available upon request); or
– A single insurer.
- If different from the basis on which the insurance was incepted the I2D representative must advise whether they will:
– Advise and make a personal recommendation after they have assessed the customer’s needs; or
– Not provide advice or a recommendation.
- The I2D representative must confirm any changes to the terms and conditions of the policy. If there have been no changes to the policy terms and conditions at renewal the I2D representative should consider confirming the same to the insured.
- The I2D representative must confirm any changes advised by the insurer, including any changes in the way the insurer operates or any changes in the manner in which the insurer handles the insurance that may affect the customer.
- The I2D representative must confirm the premiums, fees, ongoing administration charges, tax and the total amount due for all insurance products and services.
- The I2D representative must provide clear and appropriate information on the payment options, including the different costs associated with these payment options including interest charges, the APR, the cost of paying by instalments and any credit arrangements. The cash price for any policy should be clearly stated.
- If requested by the customer I2D’s commission must be disclosed promptly.
- Any renewal information which is given verbally to the customer must be promptly confirmed in writing or other durable medium prior to conclusion of the renewal. If it is not possible to provide the information in writing or other durable medium prior to conclusion of the renewal it must be provided immediately after.
- Renewal documentation should be issued promptly in line with ABI Contract Certainty Guidelines.
A general insurance policy which is arranged on the basis of:
a) a personal recommendation being given by the intermediary and/or
b) a fair analysis of the market
may be renewed on a ‘non-advised’ basis with a ‘fair analysis’ of the market not being undertaken as long as the demands and needs statement is re-issued and the renewal letter shows the new basis of the sale. This means that at renewal, an intermediary may offer only the existing Insurers’ terms, without a recommendation, as long as the information mentioned above is supplied to the client.
Following confirmation from the customer that the policy (ies) is/are to be renewed I2D must:
- Confirm renewal in writing to all insurers and request acknowledgement of the same or accept the online renewal quotations.
- On receipt of confirmation from insurers that the policy(ies) have been renewed, confirm the same in writing to the client.
- Update the internal records, such as the client register, to reflect renewal.
- The insurer’s renewal documents and an up to date client register (if appropriate) must be issued promptly in line with ABI Contract Certainty Guidelines. (within 30 Days). Where this is not possible a diary entry must be made.