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Page 1 of 55
Conduct of Business Returns (“CBR’s”)
Revised Categorisation, questions and reporting levels
Response to industry comments
EXECUTIVE SUMMARY
This document provides a guide to the revised draft Conduct of Business Returns (“CBR’s”)
released for public comment, following consideration of comments received on the previous
draft and alignment with the proposed prudential regulatory reporting requirements in terms
of the future Solvency Assessment and Management (“SAM”) framework.
The CBR’s are a new set of market conduct returns that will need to be completed by all life
and non-life insurers in South Africa, excluding reinsurers and captive insurers1.
The CBR’s will form part of the off-site supervision framework for insurers, with the aim of
providing the Financial Services Board (“FSB”) with a quantitative summary of key market
conduct risk indicators. The market conduct risk indicators have been informed by various
data sources, such as on-site visits, complaints information and local and international policy
and regulatory developments. These indicators will be reviewed on an annual basis to
ensure that they remain relevant.
The CBR’s will feed into the overall market conduct risk-based supervision framework, which
contemplates the development of conduct risk profiles for individual insurers and groups.
The first version of the draft CBR’s was sent out to industry associations for comments on 31
October 2013. The CBR’s have been significantly revised subsequent to the consideration of
comments received from various stakeholders and industry consultation workshops held with
the South African Insurance Association (“SAIA”), the Association for Savings and
Investment South Africa (“ASISA”) and other industry representatives. The reporting classes
of the CBR’s have also been aligned, as far as reasonably possible, to the reporting classes
contained in the SAM draft reporting templates and the classes and sub-classes of insurance
business set out in Schedule 2 of the Insurance Bill, 2015. Although largely aligned, there
will be some differences between the granularity of reporting information required for
purposes of prudential supervision and market conduct supervision respectively, due to the
different supervisory objectives sought to be achieved in each case.
In order to monitor key conduct outcomes, the reporting classes are broken down into more
granular benefit or cover types for the purposes of the CBR’s.
1 A captive insurer refers to an insurer that only insures first party risks. First party risks in respect of a captive insurer means the operational risks of
(i) the group of companies of which the insurer is a part; (ii) any associate of a company that is part of the group of companies referred to in (i); or (iii) any joint arrangement that a company that is part of the group of companies referred to in
paragraph (i) participates in.
CBR’s – Response to industry comments
Page 2 of 55
The updated draft CBR’s consist of a number of sheets depending on the number of classes
of business underwritten by a specific insurer. For each sheet, the columns reflect the
benefit or cover types per class of business. The breakdown of these benefits or cover types
per class of business are provided in section 4 below.
Each return also contains sheets containing instructions on how to complete the returns, an
explanation of terminology used, a declaration that must be signed on behalf of the insurer
and a general sheet. The general sheet contains questions relating to remuneration for
outsourced activities, advertising and marketing expenditure and complaints management.
An additional section has been added with questions relating to add-on or rider benefits.
Below is a brief explanation of the rationale behind the information requested in each section
of the CBR’s:
1. Business Composition
This section focuses on identifying trends in the sales, lapses, “not taken up’s” and
cancellation of policies depending on the different distribution channels of the insurer.
It will provide information regarding possible mis-selling, growth in different channels
of business, movement of policies in the industry and the chosen distribution channel
for different target markets.
2. Distribution and Binder Costs
Statistics on commission payments will enable the monitoring of regulatory caps and
provide an indicator of the size of each distribution channel used by an insurer.
Statistics on the binder and other fees paid, such as aggregation fees, will provide
valuable information regarding the reliance placed on third parties and the total
expenditure in each instance.
3. Claims Management
This section requests information on the number and value of claims submitted, as
well as the number of repudiated and outstanding claims, to enable the monitoring of
an insurer’s performance in relation to efficient and fair claims handling.
4. Complaints Handling
Reporting on complaints management is split between the main sheets and the
general sheet as indicated above. The complaints management information will
assist in identifying trends, root causes for complaints and areas for improvement
relating to products sold or services rendered to the customer. The categories used
are aligned with the categories identified as part of the TCF complaints management
framework as published in the “Discussion Document on Consumer Complaint
Management by regulated financial institutions, aligned to the Treating Customers
Fairly framework”.
5. Add-on/Rider Benefits
In order to ensure a complete view of all benefits offered by insurers, it is important to
understand the types of ancillary benefits being offered as well as the types of
policies to which such benefits are linked. This includes information on bundled
and/or combined products.
CBR’s – Response to industry comments
Page 3 of 55
The information provided through the CBR’s will assist the FSB to identify trends and
highlight specific market conduct risks relating to individual insurers as well as the wider
industry. It should also provide insurers with important management information to help
monitor and manage market conduct risks on an on-going basis.
The revised draft CBR’s are released for comment. The final version of the CBR’s may also
be further influenced by changes that may be required due to deliberations on the Insurance
Bill, 2015.
1. INTRODUCTION, PURPOSE AND SCOPE
The purpose of this document is to provide a guide to the revised draft CBR’s following
consideration of comments received on the previous draft and alignment with proposed SAM
reporting templates. The document does not provide detailed feedback on each of the
comments received; in most instances the comments have been incorporated into the
revised version of the CBR’s.
This document outlines:
the breakdown of the reporting classes;
the questions contained in the returns; and
an indication of the level of reporting class at which the various questions need to be answered.
The above mentioned classes, questions and levels of reporting are set out separately for
Life and Non-life insurers in section 4 of the document below. A guide to the terminology
used in the returns is attached hereto in two separate documents (for life and for non-life) to
serve as supporting documents for the CBR’s.
2. REPORTING REQUIREMENTS
The final CBR’s will be required to be completed electronically and submitted via the
“Electronic Submission” portal on the FSB’s website. The CBR’s will need to be submitted
quarterly, but a two-year phasing-in period will apply during which the reporting period will be
bi-annual. All submissions will need to be received via the portal within 60 days after the end
of the relevant period.
It is accepted that it may not be possible to complete the returns in full or with the adequate
level of detail immediately upon implementation. However, the FSB would prefer to accept
incomplete returns upfront and monitor progress over time rather than a phased
implementation. This will enable the FSB to monitor the progress of individual insurer’s with
respect to system development, implementation of systems and analysis of data with the
submission of each return.
CBR’s – Response to industry comments
Page 4 of 55
3. INVITATION TO COMMENT, PROJECT PILOT AND PLANNED IMPLEMENTATION DATE
The practical implementation of the CBR’s will have three components. Firstly, all life and
non-life insurers are invited to comment on the revised categorisation, level of reporting and
questions in the CBR’s as contained in this document. Comments must be submitted to the
FSB c/o [email protected] on or before 18 March 2016.
In addition, the Deputy Registrar will request SAIA and ASISA to submit the names of
insurers who wish to participate in a pilot project to test the functionality and practical
effectiveness of this version of the CBR’s. The testing period will run concurrently with the
comment period.
Finally, all feedback from the pilot project will be taken into consideration together with the
general comments received from the industry to inform possible further amendments. The
planned implementation date for the final version of the CBR’s is June 2016.
Page 5 of 55
4. REPORTING LEVELS FOR CBR’S
This section sets out the recommended reporting levels for the CBR’s, as amended and aligned to the SAM reporting classes as set out in Schedule
2 of the Insurance Bill 2015, but at a more granular level in some cases.
4.1. TABLE: LIFE INSURANCE
Levels 1 and 2 are aligned to the classes and sub-classes in the Insurance Bill. Reporting on levels 2, 4 and 5 is required in the instances set out in
section 4.2 below, where further information is required on specific cover types and or benefits.
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
1. RISK a. Individual Death Individually risk rated
Underwritten on a group
basis
b. Individual Health Individually risk rated Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
CBR’s – Response to industry comments
Page 6 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
evacuation or transport
Underwritten on a group
basis
Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
c. Individual Disability
– lump sum
Individually risk rated Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Underwritten on a group
basis
Own occupation
disability
Own/similar
CBR’s – Response to industry comments
Page 7 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
occupation disability
Total disability
Functional Impairment
d. Individual Disability
– recurring
payment
Individually risk rated Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Underwritten on a group
basis
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
e. Group Death
f. Group Health Non-medical expense
cover as a result of
CBR’s – Response to industry comments
Page 8 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
g. Group Disability –
lump sum
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
h. Group Disability –
recurring payment
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
CBR’s – Response to industry comments
Page 9 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
2.
FUND RISK a. Death
b. Disability – lump
sum
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
c. Disability –
recurring payment
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
3.
CREDIT LIFE a. Individually risk
rated
Mandatory Death;
Disability (lump sum);
Own occupation
disability
Own/similar
occupation disability
CBR’s – Response to industry comments
Page 10 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
Total disability
Functional Impairment
Disability (recurring);
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Health (lump sum); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring); Non-medical expense
cover as a result of
CBR’s – Response to industry comments
Page 11 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Retrenchment
Other
Optional Death;
Disability (lump sum); Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Disability (recurring); Own occupation
disability
Own/similar
CBR’s – Response to industry comments
Page 12 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
occupation disability
Total disability
Functional Impairment
Health (lump sum); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
CBR’s – Response to industry comments
Page 13 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
and treatment
Medical emergency
evacuation or transport
Retrenchment
Other
b. Underwritten on a
group basis
Mandatory Death;
Disability (lump sum); Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Disability (recurring); Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
CBR’s – Response to industry comments
Page 14 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
Health (lump sum); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Retrenchment
CBR’s – Response to industry comments
Page 15 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
Other
Optional Death;
Disability (lump sum);
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Disability (recurring);
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Health (lump sum);
Non-medical expense
cover as a result of
hospitalisation
Frail care
CBR’s – Response to industry comments
Page 16 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring); Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Retrenchment
Other
4. FUNERAL a. Individual Individually risk rated
Individual underwritten on a
CBR’s – Response to industry comments
Page 17 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
group basis
b. Group
5. LIFE ANNUITIES a. With Discretionary
Participation
features
b. Other
6. INDIVIDUAL
INVESTMENT
a. With Discretionary
Participation
features
Fund member policies Retirement annuities
Preservation funds
Endowment policies
Other
b. Other Fund member policies Retirement annuities
Preservation funds
Endowment policies
Other
7. FUND INVESTMENT a. With Discretionary
Participation
features
CBR’s – Response to industry comments
Page 18 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
b. Other
8. INCOME DRAWDOWN a. With Discretionary
Participation
features
b. Other
9.
COMBINED POLICIES
a. Universal Life With Discretionary
Participation features
Death;
Disability (lump sum);
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Disability (recurring);
Own occupation
disability
Own/similar
occupation disability
Total disability
CBR’s – Response to industry comments
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LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
Functional Impairment
Health (lump sum);
Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring);
Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
CBR’s – Response to industry comments
Page 20 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
Other
b. Fund Member
Policies
With Discretionary
Participation features
Death
Disability (lump sum)
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Disability (recurring)
Own occupation
disability
Own/similar
occupation disability
Total disability
Functional Impairment
Health (lump sum)
Non-medical expense
cover as a result of
hospitalisation
Frail care
CBR’s – Response to industry comments
Page 21 of 55
LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 LEVEL5
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Health (recurring)
Non-medical expense
cover as a result of
hospitalisation
Frail care
HIV, Aids, tuberculosis
and malaria testing
and treatment
Medical emergency
evacuation or transport
Other
CBR’s – response to industry comments
Page 22 of 55
4.2 QUESTIONS AND REPORTING LEVEL FOR LIFE INSURERS
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1 BUSINESS COMPOSITION
1.1 State the number of policies in force at the end of the quarter.
X
1.2 State the number of benefits in force at the end of the quarter.
X X
1.3 State the total gross written premium for all policies in force at the end of the quarter.
X
1.4 State the number of new policies issued in the quarter.
X
1.5 State the number of new benefits issued in the quarter.
X X
1.6 State the total gross written premium for all new policies issued in the quarter.
X
1.7 State the number of new policies issued in the quarter as per the income group breakdown below:
X
1.7.1 Low income; X
1.7.2 Middle income; X
1.7.3 Upper income. X
1.8 State the number of new policies issued in the quarter as per the breakdown below:
X
1.8.1 Direct marketing via telesales/call centre of the insurer;
X
1.8.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.8.3 Direct marketing via telesales/call centres of any other third party;
X
1.8.4 Direct marketing via internet; X
1.8.5 Marketing via aggregator and/or lead generator;
X
1.8.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.8.7 Face-to-face by insurer's juristic representatives;
X
1.8.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
CBR’s – Response to industry comments
Page 23 of 55
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.8.9 Other (please specify). X
1.9 State the gross written premium for new policies issued in the quarter as per the breakdown below:
X
1.9.1 Direct marketing via telesales/call centre of the insurer;
X
1.9.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.9.3 Direct marketing via telesales/call centres of any other third party;
X
1.9.4 Direct marketing via internet; X
1.9.5 Marketing via aggregator and/or lead aggregators;
X
1.9.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.9.7 Face-to-face by insurer's juristic representatives;
X
1.9.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.9.9 Other (please specify). X
1.10
State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the breakdown below:
X
1.10.1 Direct marketing via telesales/call centre of the insurer;
X
1.10.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.10.3 Direct marketing via telesales/call centres of any other third party;
X
1.10.4 Direct marketing via internet; X
1.10.5 Marketing via aggregator and/or lead generator;
X
1.10.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.10.7 Face-to-face by insurer's juristic representatives;
X
CBR’s – Response to industry comments
Page 24 of 55
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.10.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.10.9 Other (please specify). X
1.11
State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the income group breakdown below:
X
1.11.1 Low income; X
1.11.2 Middle income; X
1.11.3 Upper income. X
1.12
State the number of policies cancelled on the instruction of the policyholder (excluding cancelled in “cooling off period”) during the quarter.
X
1.13 State the number of policies cancelled on the instruction of the insurer during the quarter.
X
1.14 State the number of policies which were cancelled in terms of “cooling off” provisions during the quarter
X
1.15 State the number of policies less than 12 months old that lapsed in the quarter as per the breakdown below:
X
1.15.1 Direct marketing via telesales/call centre of the insurer;
X
1.15.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.15.3 Direct marketing via telesales/call centres of any other third party;
X
1.15.4 Direct marketing via internet; X
1.15.5 Marketing via aggregator and/or lead generator;
X
1.15.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.15.7 Face-to-face by insurer's juristic representatives;
X
CBR’s – Response to industry comments
Page 25 of 55
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.15.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.15.9 Other (please specify). X
1.16 State the number of policies less than 12 months old that lapsed in the quarter as per the income group breakdown below:
X
1.16.1 Low income; X
1.16.2 Middle income; X
1.16.3 Upper income. X
1.17 State the number of policies between 12 and 24 months old that lapsed in the quarter.
X
1.18
State the number of policies between 12 and 24 months old that lapsed in the quarter as per the income group breakdown below:
X
1.18.1 Low income; X
1.18.2 Middle income; X
1.18.3 Upper income. X
1.19 State the number of policies older than 24 months that lapsed in the quarter.
X
1.20 State the number of policies older than 24 months that lapsed in the quarter as per the income group breakdown below:
X
1.20.1 Low income; X
1.20.2 Middle income; X
1.20.3 Upper income. X
1.21 State the number of benefits that were cancelled by the policyholder in the quarter.
X X
1.22 State the number of policies less than 12 months old made paid-up in the quarter as per the breakdown below:
X
1.22.1 Direct marketing via telesales/call centre of the insurer;
X
1.22.2 Direct marketing via telesales/call centre of affinity schemes;
X
CBR’s – Response to industry comments
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.22.3 Direct marketing via telesales/call centres of any other third party;
X
1.22.4 Direct marketing via internet; X
1.22.5 Marketing via aggregator and/or lead generator;
X
1.22.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.22.7 Face-to-face by insurer's juristic representatives;
X
1.22.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.22.9 Other (please specify). X
1.23 State the number of policies less than 12 months old made paid-up in the quarter as per the income group breakdown below:
X
1.23.1 Low income; X
1.23.2 Middle income; X
1.23.3 Upper income. X
1.24 State the number of policies between 12 and 24 months old made paid-up in the quarter.
X
1.25
State the number of policies between 12 and 24 months old made paid-up in the quarter as per the income group breakdown below:
X
1.25.1 Low income; X
1.25.2 Middle income; X
1.25.3 Upper income. X
1.26 State the number of policies older than 24 months made paid-up in the quarter.
X
1.27 State the number of policies older than 24 months made paid-up in the quarter as per the income group breakdown below:
X
1.27.1 Low income; X
1.27.2 Middle income; X
1.27.3 Upper income. X
CBR’s – Response to industry comments
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.28 State the number of policies surrendered in the quarter as per the breakdown below:
X
1.28.1 Direct marketing via telesales/call centre of the insurer;
X
1.28.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.28.3 Direct marketing via telesales/call centres of any other third party;
X
1.28.4 Direct marketing via internet; X
1.28.5 Marketing via aggregator and/or lead generator;
X
1.28.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.28.7 Face-to-face by insurer's juristic representatives;
X
1.28.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.28.9 Other (please specify). X
1.29
State the number of policies surrendered, as indicated above, which was due to replacement in the quarter as per the breakdown below:
X
1.29.1 Direct marketing via telesales/call centre of the insurer;
X
1.29.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.29.3 Direct marketing via telesales/call centres of any other third party;
X
1.29.4 Direct marketing via internet; X
1.29.5 Marketing via aggregator and/or lead generator;
X
1.29.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.29.7 Face-to-face by insurer's juristic representatives;
X
CBR’s – Response to industry comments
Page 28 of 55
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.29.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.29.9 Other (please specify). X
1.30 State the number of policies surrendered in the quarter as per the income group breakdown below:
X
1.30.1 Low income; X
1.30.2 Middle income; X
1.30.3 Upper income. X
1.31 State the number of policies transferred in the quarter as per the breakdown below:
X
1.31.1 Direct marketing via telesales/call centre of the insurer;
X
1.31.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.31.3 Direct marketing via telesales/call centres of any other third party;
X
1.31.4 Direct marketing via internet; X
1.31.5 Marketing via aggregator and/or lead generator;
X
1.31.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.31.7 Face-to-face by insurer's juristic representatives;
X
1.31.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.31.9 Other (please specify). X
1.32 State the number of policies transferred in the quarter as per the income group breakdown below:
X
1.32.1 Low income; X
1.32.2 Middle income; X
1.32.3 Upper income. X
1.33 State the number of new policies, which were replacement policies, issued in the quarter, as per the breakdown below:
X
CBR’s – Response to industry comments
Page 29 of 55
LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
1.33.1 Direct marketing via telesales/call centre of the insurer;
X
1.33.2 Direct marketing via telesales/call centre of affinity schemes;
X
1.33.3 Direct marketing via telesales/call centres of any other third party;
X
1.33.4 Direct marketing via internet; X
1.33.5 Marketing via aggregator and/or lead generator;
X
1.33.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
1.33.7 Face-to-face by insurer's juristic representatives;
X
1.33.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.33.9 Other (please specify). X
2 DISTRIBUTION AND BINDER COSTS
2.1 Please state the total commission paid in the quarter as per the breakdown below:
X
2.1.1 Direct marketing via telesales/call centre of the insurer;
X
2.1.2 Direct marketing via telesales/call centre of affinity schemes;
X
2.1.3 Direct marketing via telesales/call centres of any other third party;
X
2.1.4 Direct marketing via internet; X
2.1.5 Marketing via aggregator and/or lead generator;
X
2.1.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
2.1.7 Face-to-face by insurer's juristic representatives;
X
2.1.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
2.1.9 Other (please specify). X
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
2.2 Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below:
X
2.2.1 Enter into, vary or renew a policy; X
2.2.2 Determining wording of a policy; X
2.2.3 Determining premiums under a policy; X
2.2.4 Determining the value of benefits under a policy;
X
2.2.5 Settling a claim under a policy. X
2.3
Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.
X
3 CLAIMS MANAGEMENT
3.1 State the number of claims that were reported to the insurer in the quarter.
X X
3.2 State the value of claims that were reported in the quarter.
X X
3.3 State the number of claims that were paid in the quarter.
X X
3.4 State the value of claims that were paid in the quarter.
X X
3.5 State the number of claims that were repudiated in the quarter.
X X
3.6 State the value of claims that were repudiated in the quarter.
X X
3.7 State the number of claims outstanding at the end of the quarter.
X X
3.8 State the value of claims outstanding at the end of the quarter.
X X
4 COMPLAINTS HANDLING
4.1 State the number of complaints received in the quarter as per the breakdown below:
4.1.1
Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits);
X
4.1.2 Complaints relating to product performance (including but not limited to investment
X
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
performance);
4.1.3 Complaints relating to product accessibility, changes or switches (including termination charges);
X
4.1.4 Complaints relating to claims, in relation to: X
4.1.4.1 Claim handling process; X
4.1.4.2 Claims repudiated. X
5 ADD-ON/RIDER BENEFITS
5.1 Do you offer any of the following benefits as add-on/rider benefits to the policies? X
5.1.1 Retrenchment; X
5.1.2 Emergency evacuation/transport; X
5.1.3 Legal Expenses; X
5.1.4 Cash back/No claim; X
5.1.5 Loyalty benefit as part of product; X
5.1.6 Loyalty benefit as part of separate program;
X
5.1.7 Other (please specify). X
5.2 State the number of policies with the add-on/rider benefits as per the breakdown below:
X
5.2.1 Retrenchment; X
5.2.2 Emergency evacuation/transport; X
5.2.3 Legal Expenses; X
5.2.4 Cash back/No claim; X
5.2.5 Loyalty benefit as part of product; X
5.2.6 Loyalty benefit as part of separate program;
X
5.2.7 Other (please specify). X
GENERAL SHEET
1 PAYMENTS
1.1 Please state the total outsourcing fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.
X
1.2 Please state the total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown
X
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
below:
1.2.1 Television; X
1.2.2 Radio; X
1.2.3 Print media; X
1.2.4 Social media; X
1.2.5 Other. X
1.3
Please indicate where possible, the percentage of total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown below:
1.3.1 Television; X
1.3.2 Radio; X
1.3.3 Print media; X
1.3.4 Social media; X
1.3.5 Other. X
2 COMPLAINTS
2.1 State the number of all complaints received in the quarter.
X
2.2 State the number of complaints received in the quarter as per the breakdown below:
X
2.2.1
Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures);
X
2.2.2 Complaints relating to service; X
2.2.3 Complaints relating to advice in respect of each of the following distribution channels:
X
2.2.3.1 Insurer's "face-to-face" representatives;
X
2.2.3.2 Insurer's call centre representatives;
X
2.2.3.3 Independent FSP's X
2.2.3.4 Other X
2.2.4 Complaints relating to complaints handling process;
X
2.2.5 Other complaints. X
2.3 State the number of all complaints finalised in favour of the policyholder in the quarter.
X
2.4 State the number of all complaints X
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LIFE INSURERS
LEVEL OF QUESTIONS
SUB
LEVEL SUB
LEVEL SUB
LEVEL
2 4 5
outstanding at the end of the quarter.
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4.3. TABLE: NON-LIFE INSURANCE
Levels 1 and 2 are aligned to the classes and sub-classes in the Insurance Bill. Reporting on level 3 is required in the instances set out in section 4.4
below, where further information is required on specific cover types and or benefits.
LEVEL 1 LEVEL 2 LEVEL 3
1. MOTOR a. Personal lines Comprehensive;
3rd Party;
3rd Party, fire & theft;
Other
b. Commercial lines Comprehensive;
3rd Party;
3rd Party, fire & theft;
Other
2. PROPERTY a. Personal lines Contents;
Specified items;
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LEVEL 1 LEVEL 2 LEVEL 3
Building structure;
Other
b. Commercial lines Contents;
Specific item;
Building structure;
Business interruption;
Other
3. AGRICULTURE a. Personal Lines Crop;
Equipment;
Other
b. Commercial lines Crop;
Equipment;
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LEVEL 1 LEVEL 2 LEVEL 3
Other
4. ENGINEERING
5. MARINE a. Personal lines
b. Commercial lines
6. AVIATION a. Personal lines
b. Commercial lines
7. TRANSPORT a. Personal lines
b. Commercial lines
8. RAIL
9. LEGAL EXPENSE a. Personal lines
b. Commercial lines
10. LIABILITY Directors and officers
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LEVEL 1 LEVEL 2 LEVEL 3
Employer liability
Product liability
Professional indemnity
Public liability
Aviation
Engineering
Marine
Motor
Rail
Transport
Personal
Other
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LEVEL 1 LEVEL 2 LEVEL 3
11. CONSUMER CREDIT a. Personal Lines - Mandatory Accident & Health;
Motor;
Property: Specified items;
Property: Building structure;
Credit Shortfall;
Other
b. Personal Lines – Optional Accident & Health;
Motor;
Property: Specified items;
Property: Building structure;
Credit Shortfall;
Other
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LEVEL 1 LEVEL 2 LEVEL 3
c. Personal lines - Other
d. Commercial lines - Mandatory Accident & Health;
Motor;
Property: Specified items;
Property: Building structure;
Credit Shortfall;
Other
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LEVEL 1 LEVEL 2 LEVEL 3
e. Commercial lines - Optional Accident & Health;
Motor;
Property: Specified items;
Property: Building structure;
Credit Shortfall;
Other
f. Commercial lines - Other
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LEVEL 1 LEVEL 2 LEVEL 3
12. TRADE CREDIT
13. GUARANTEE a. Commercial lines
14. ACCIDENT AND HEALTH a. Individual - Personal lines Medical expense shortfall cover
(Gap Cover);
Non-medical expense cover as a result of hospitalisation (Hospital Cash Back);
HIV, Aids, tuberculosis and
malaria testing and treatment;
International travel insurance;
Medical emergency evacuation or
transport
b. Individual - Commercial lines
Medical expense shortfall cover
(Gap Cover);
Non-medical expense cover as a result of hospitalisation (Hospital Cash Back);
CBR’s – Response to industry comments
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LEVEL 1 LEVEL 2 LEVEL 3
HIV, Aids, tuberculosis and
malaria testing and treatment;
International travel insurance;
Medical emergency evacuation or
transport
c. Group Medical expense shortfall cover
(Gap Cover);
Non-medical expense cover as a result of hospitalisation (Hospital Cash Back);
HIV, Aids, tuberculosis and
malaria testing and treatment;
International travel insurance;
Medical emergency evacuation or
transport
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LEVEL 1 LEVEL 2 LEVEL 3
15. TRAVEL a. Individual - Personal lines
Loss of Property (including
baggage);
Cancellation;
Interruption;
Death, disability or health event
while travelling
b. Individual - Commercial lines Loss of Property (including
baggage);
Cancellation;
Interruption;
Death, disability or health event
while travelling
c. Group Loss of Property (including
baggage);
Cancellation;
CBR’s – Response to industry comments
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LEVEL 1 LEVEL 2 LEVEL 3
Interruption;
Death, disability or health event
while travelling
16. MISCELLANEOUS a. Personal Lines Warranty;
Pet Insurance;
Other
b. Commercial lines Warranty;
Other
17. PERSONAL LINES POLICY WITH MULTIPLE COVER TYPES
Motor: Comprehensive;
Motor: 3rd Party;
Motor: 3rd Party, fire & theft;
Motor: Other;
Property: Contents;
CBR’s – Response to industry comments
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LEVEL 1 LEVEL 2 LEVEL 3
Property: Specified items;
Property: Building structure;
Property: Other;
Legal Expense;
A&H: Personal accident;
A&H: Health event other than accident;
Miscellaneous: Warranty;
Miscellaneous: Other.
18. COMMERCIAL LINES POLICY WITH MULTIPLE COVER TYPES
Motor: Comprehensive;
Motor: 3rd Party;
Motor: 3rd Party, fire & theft;
Motor: Other;
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LEVEL 1 LEVEL 2 LEVEL 3
Property: Contents;
Property: Specified items;
Property: Building structure;
Property: Business interruption;
Property: Other;
Agriculture: Crop;
Agriculture: Equipment;
Agriculture: Other;
Legal Expense;
Liability: Directors and officers;
Liability: Employer liability;
Liability: Product liability;
CBR’s – Response to industry comments
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LEVEL 1 LEVEL 2 LEVEL 3
Liability: Professional indemnity;
Liability: Public liability;
Liability: Other;
A&H: Personal accident;
A&H: Health event other than accident;
Miscellaneous: Warranty;
Miscellaneous: Other.
CBR’s – response to industry comments
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4.4 QUESTIONS AND REPORTING LEVEL FOR NON-LIFE INSURERS
NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
1 BUSINESS COMPOSITION
1.1 State the number of policies in force at the end of the quarter. X
1.2 State the number of cover types in force at the end of the quarter.
X
1.3 State the total gross written premium for all policies in force at the end of the quarter. X
1.4 State the number of new policies issued in the quarter. X
1.5 State the number of new cover types issued in the quarter.
X
1.6 State the total gross written premium for all new policies issued in the quarter. X
1.7 State the number of policies issued in the quarter as per the income group breakdown below:
X
1.7.1 Low income; X
1.7.2 Middle income; X
1.7.3 Upper income. X
1.8 State the number of new policies issued in the quarter as per the breakdown below: X
1.8.1 Direct marketing via telesales/call centre of the insurer; X
1.8.2 Direct marketing via telesales/call centre of affinity schemes; X
1.8.3 Direct marketing via telesales/call centres of any other third party; X
1.8.4 Direct marketing via internet; X
1.8.5 Marketing via aggregator and/or lead generator; X
1.8.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X
1.8.7 Face-to-face by insurer's juristic representatives; X
1.8.8
Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
1.8.9 Other (please specify). X
1.9
State the gross written premium for new policies issued in the quarter as per the breakdown below:
X
1.9.1 Direct marketing via telesales/call centre of the insurer; X
1.9.2 Direct marketing via telesales/call centre of affinity schemes; X
1.9.3 Direct marketing via telesales/call centres of any other third party; X
1.9.4 Direct marketing via internet; X
1.9.5 Marketing via aggregator and/or lead generator; X
1.9.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X
1.9.7 Face-to-face by insurer's juristic representatives; X
1.9.8
Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.9.9 Other (please specify). X
1.10
State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the breakdown below:
X
1.10.1 Direct marketing via telesales/call centre of the insurer; X
1.10.2 Direct marketing via telesales/call centre of affinity schemes; X
1.10.3 Direct marketing via telesales/call centres of any other third party; X
1.10.4 Direct marketing via internet; X
1.10.5 Marketing via aggregator and/or lead generator; X
1.10.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X
1.10.7 Face-to-face by insurer's juristic representatives; X
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
1.10.8
Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.10.9 Other (please specify). X
1.11
State the number of policies recorded during the quarter as "not taken up" due to non-payment of premiums, as per the income group breakdown below:
X
1.11.1 Low income; X
1.11.2 Middle income; X
1.11.3 Upper income. X
1.12 State the number of policies cancelled by the policyholder in the quarter. X
1.13 State the number of policies cancelled by the insurer in the quarter. X
1.14 State the number of all policies lapsed during the quarter. X
1.15
State the gross written premium for all policies lapsed during the quarter as per the breakdown below:
X
1.15.1 Direct marketing via telesales/call centre of the insurer; X
1.15.2 Direct marketing via telesales/call centre of affinity schemes; X
1.15.3 Direct marketing via telesales/call centres of any other third party; X
1.15.4 Direct marketing via internet; X
1.15.5 Marketing via aggregator and/or lead generator; X
1.15.6 Face-to-face by insurer’s own individual representatives (“tied agents”); X
1.15.7 Face-to-face by insurer's juristic representatives; X
1.15.8
Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
1.15.9 Other (please specify). X
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
1.16 State the number of policies lapsed in the quarter as per the income group breakdown below:
X
1.16.1 Low income; X
1.16.2 Middle income; X
1.16.3 Upper income. X
1.17 State the number of cover types cancelled by the policyholder in the quarter.
X
2 DISTRIBUTION AND BINDER COSTS
2.1 Please state the total commission paid in the quarter as per the breakdown below:
X
2.1.1 Direct marketing via telesales/call centre of the insurer;
X
2.1.2 Direct marketing via telesales/call centre of affinity schemes;
X
2.1.3 Direct marketing via telesales/call centres of any other third party;
X
2.1.4 Direct marketing via internet; X
2.1.5 Marketing via aggregator and/or lead generator;
X
2.1.6 Face-to-face by insurer’s own individual representatives (“tied agents”);
X
2.1.7 Face-to-face by insurer's juristic representatives;
X
2.1.8 Face-to-face by independent intermediaries (FSP’s that are not representatives of the insurer);
X
2.1.9 Other (please specify). X
2.2 Please state the binder fees paid to all binder holders in the quarter as per the breakdown of binder functions below:
X
2.2.1 Enter into, vary or renew a policy; X
2.2.2 Determining wording of a policy; X
2.2.3 Determining premiums under a policy; X
2.2.4 Determining the value of benefits under a
policy; X
2.2.5 Settling a claim under a policy. X
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
2.3 Please state the total aggregation fees paid to all other parties, including intermediaries and Underwriting Managers, in the quarter.
X
3 CLAIMS MANAGEMENT
3.1 State the number of claims that were reported to the insurer in the quarter.
X
3.2 State the value of claims that were reported in the quarter.
X
3.3 State the number of claims that were paid in the quarter.
X
3.4 State the value of claims that were paid in the quarter.
X
3.5 State the number of claims that were repudiated in the quarter.
X
3.6 State the value of claims that were repudiated in the quarter.
X
3.7 State the number of claims outstanding at the end of the quarter.
X
3.8 State the value of claims outstanding at the end of the quarter.
X
4 COMPLAINTS HANDLING
4.1 State the number of complaints received in the quarter as per the breakdown below:
4.1.1 Complaints relating to product design (including premiums, charges, other product features, bundled, "add-on" or loyalty benefits);
X
4.1.2 Complaints relating to product performance (including but not limited to investment performance);
X
4.1.3 Complaints relating to product accessibility, changes or switches (including termination charges);
X
4.1.4 Complaints relating to claims, in relation to: X
4.1.4.1 Claim handling process; X
4.1.4.2 Claims repudiated. X
5 ADD-ON/RIDER BENEFITS
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
5.1 Do you offer any of the following benefits as add-on/rider benefits to the policies? X
5.1.1 Emergency evacuation/transport; X
5.1.2 Legal Expenses; X
5.1.3 Riots and strikes; X
5.1.4 Cash back/No claim; X
5.1.5 Loyalty benefit as part of the product; X
5.1.6 Loyalty benefit as part of separate program; X
5.1.7 Other (please specify). X
5.2 State the number of policies with the add-on/rider benefits as per the breakdown below:
X
5.2.1 Emergency evacuation/transport; X
5.2.2 Legal Expenses; X
5.2.3 Riots and strikes; X
5.2.4 Cash back/No claim; X
5.2.5 Loyalty benefit as part of the product; X
5.2.6 Loyalty benefit as part of separate program; X
5.2.7 Other (please specify). X
CBR’s – Response to industry comments
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NON-LIFE INSURERS
LEVEL OF QUESTIONS
MAIN LEVEL
SUB LEVEL
1 3
GENERAL SHEET
1 PAYMENTS
1.1 Please state the total outsourcing fees paid to all other parties, including intermediaries and Underwriting Managers, in the last quarter.
X
1.2 Please state the total advertising and marketing expenses paid to all other parties in the last quarter as per the breakdown below:
X
1.2.1 Television X
1.2.2 Radio X
1.2.3 Print media X
1.2.4 Social media X
1.2.5 Other X
1.3
Please indicate where possible, the percentage of total advertising and marketing expenses paid to all other parties in the quarter as per the breakdown below:
1.3.1 Television X
1.3.2 Radio X
1.3.3 Print media X
1.3.4 Social media X
1.3.5 Other X
2 COMPLAINTS
2.1 State the number of all complaints received in the quarter.
X
2.2 State the number of complaints received in the quarter as per the breakdown below:
X
2.2.1
Complaints relating to information provided (including advertising material, policy documents, service letters and other disclosures);
X
2.2.2 Complaints relating to service; X
2.2.3 Complaints relating to advice in respect of each of the following distribution channels:
X
2.2.3.1 Insurer's "face-to-face" representatives;
X
2.2.3.2 Insurer's call centre representatives; X
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2.2.3.3 Independent FSP's X
2.2.3.4 Other
2.2.4 Complaints relating to complaints handling process;
X
2.2.5 Other complaints. X
2.3 State the number of all complaints finalised in favour of the policyholder in the quarter.
X
2.4 State the number of all complaints outstanding at the end of the quarter.
X