Regulatory Timeline: General Insurance Pricing Practices
Status: Policy Statement and Final Rules issued.
Regulator: FCA
The FCA focus on pricing was precipitated by the Citizens Advice supercomplaint to the Competition and Markets Authority in September 2018. Amongst the 5 markets, Citizens Advice complained that in their view, harm was being caused to consumers through a loyalty penalty in the motor and household insurance markets. The FCA responded with various reviews, culminating in their Policy Statement and Final Rules issued on 24th May 2021. The new rules cover:
- A pricing remedy;
- Enhancements to product governance;
- Rules to offer a range of accessible and easy options for consumers who want to cancel auto renewal contracts;
- Reporting requirements for home and motor insurance markets.
The General Insurance Pricing Practices (GIPP) rules came into effect from 1st January 2022 and had a significant impact on pricing within the home and motor insurance sectors, aiming to tackle ‘price walking’ and to prevent the unfair treatment of loyal and potentially vulnerable customers. In December 2022, the FCA published its findings from an assessment of how firms had risen to the rule changes; findings were mixed, with deficiencies reported in relation to evidencing compliance and record keeping.
All insurance firms should by now be familiar with the rules and annual reporting requirements, and understand the implications for their Product Governance processes and any products which included auto-renewal clauses.
There are links with the work on Consumer Duty, Distribution and Vulnerable Customers which firms should be conscious of.
This timeline provides key dates in the regulatory calendar and links to ICSR articles and webinars on the subject. If you would like to discuss any aspects of General Insurance Pricing, please contact us.
Implementation Period - Reporting Requirements
The FCA have introduced new reporting requirements which require regular reports showing pricing information for home and motor insurance as well as add-ons and premium finance sold alongside these products. The reporting requirements are for Insurers, Brokers, MGA’s operating in the retail home and motor insurance products. The changes require reporting on renewals from 1st January 2022, with an attestation date of 31st March 2022 and the first data submission due for the 6-month period to 30th June 2022.
Implementation Period - Cancelling Auto-Renewal Policies
The FCA now expect firms operating in general insurance space to offer the consumer a variety of channels if they choose to opt out of their current contract upon renewal. Firm’s must implment changes to their practices by 1st January 2022.
Implementation Period - Pricing Remedy
The FCA has introduced a ‘pricing remedy’, which means firms must now offer a renewal price to a consumer that is no greater than the equivalent new business price (ENBP) offered to a new customer. The implementation deadline is 1st January 2022
Implementation Period - Product Governance
The FCA are broadening the scope of the Product Intervention and Product Governance Sourcebook (PROD) to ensure firms have processes in place to deliver products that offer fair value to customers.
PS21/11: General insurance pricing practices - amendments
In May 2021, the FCA published PS21/5 which set out final rules to address the harm they had found in the GI Pricing Practices Market Study. On 18 August, they published PS21/11, making minor changes to those rules.
Article: FCA’s New Rules Against General Insurance ‘Price Walking’
The Financial Conduct Authority (FCA) recently published its Policy Statement outlining the new rules to be implemented for General Insurance Pricing Practices (GIPP). Nicky Hasler sets out what the new rules are, who they apply to, and the impact of the new rules for the general insurance sector.
Update from FCA Following Feedback
The implementation period for any rules arising from CP20/19 has been amended following feedback. Confirmation of publication date for Policy Statement also provided.
Deadline for completing Covid-19 Product Value reviews
Firms are expected to have completed their product value reviews. Finalised Guidance sets a deadline for firms of 3rd December 2020.
Article: Pricing – ‘Fair Value’ Is Not Just A Household And Motor Issue
Price walking has dominated the headlines as the FCA, CMA and Citizens Advice have all talked about the risks of consumer harm. Kenneth Underhill looks at the issues arising from the FCA Final Report on the matter.
FCA Consultation on Proposed Handbook Changes to address harm caused by issues with General Insurance Pricing Practices
The FCA have published proposed changes to the Handbook. The changes affect not only motor and household insurance products, but also include proposed changes to the existing product governance rules in the PROD sourcebook, changes to the rules on auto-renewal for any product and new reporting requirements.
FCA Final Report Issued
The FCA Report on General Insurance Pricing Practices is released setting out its findings and proposed remedies.
FS20/7: Product Value and coronavirus: guidance for insurance firms
FCA Guidance on product value, including price, is issued in the wake of the covid-19 pandemic. Firms are instructed to undertake product value reviews, which may have an impact on their pricing models. A deadline of 3rd December is set to complete the work.
ICSR Article: Emerging Challenges for Complaints in the General Insurance Sector: Pricing Practices Within Retail General Insurance
A look at the risk of complaints arising from the pricing work undertaken by the FCA
ICSR Article: Are you walking into a price problem? General Insurance Pricing and the FCA Remedies
ICSR Director Kenneth Underhill looks at the issues following the FCA Interim Report.
FCA Interim Report Released
The FCA released their interim report on General Insurance Pricing Practices. They concluded the home and motor insurance markets were not working well for consumers and that they were “considering a range of industry wide measures to reform these markets so they work well for consumers in the future.”
FCA Terms of Reference
The FCA Terms of Reference for a Market Study were published. “This market study will deepen our understanding of consumer outcomes from pricing practices, the scale and nature of any harm and inform how to, if necessary, improve the market.”
Citizens Advice supercomplaint to the CMA
Citizens Advice lodged a super-complaint with the Competition and Markets Authority that included allegations of harm being caused to consumers on the motor and household insurance markets.
FCA Business Plan 2018/19
The FCA Business Plan in 2018/9 indicated an intention to “Understanding firms’ pricing practices in retail general insurance.”
