Regulatory Timeline: General Insurance Pricing Practices
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 the announcement of a review in October 2018 and their most recent report in September 2020 has made a number of recomendations, including a statement that “While our focus is primarily on the home and motor insurance markets, we propose to apply some of our remedies to all types of general insurance and pure protection insurance.”. All insurance firms should familiarise themselves with the proposed changes to understand the implications for their Product Governance processes and the implications if they have any products which include auto-renewal processes. There are links with the work on Insurance Distribution Directive 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.
FCA Business Plan 2018/19
The FCA Business Plan in 2018/9 indicated an intention to “Understanding firms’ pricing practices in retail general insurance.”
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 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.”
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.”
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.
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
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.
FCA Final Report Issued
The FCA Report on General Insurance Pricing Practices is released setting out its findings and proposed remedies.
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.
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.
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.
Deadline for comments on Consultation Paper
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.
FCA Policy Statement Due
The implementation period for any rules the FCA may make in relation to systems and controls (SYSC) rules and product governance rules will run to the end of September 2021.
The implementation period for any rules the FCA may make in relation to pricing and auto-renewal remedies and the reporting requirements will run to the end of December 2021.