A couple of “issues” have passed my desk recently which
leave me with a smarting sense of injustice.
Take Insurance Product Information Documents (IPID)…
My own opinion is that IPIDs are inferior to Key Facts documents in the UK because consumers will receive less information about their insurance product than they previously would have been given.
For example, where products are created by a managing
general agent, there is no requirement to show the insurer. More generally, IPIDs
do not include information about making a complaint and do not allow exclusions
that apply to a particular insured event to be lined up against the description
of that insured event. Additionally, there is no space to highlight extra
services which complement “what is insured” – such as telephone helplines and
in-line legal documents which significantly enhance the value of products for
consumers.
We have taken a very flexible approach to product
development and have delighted in designing unique features that respond to the
needs of specific target customers and give niche cover. As a consequence of
our willingness to go the extra mile, ARAG IPIDs will need to reflect the many modifications
that we have made. Our innovation has been wide-spread and we have hundreds of
“non-standard” wordings to consider. Had we adopted a more intransigent
approach and not deviated from our standard product specifications, delivering
to the exceptionally tight deadline would have been very much easier.
We also have many “embedded” policies where we have
integrated ARAG products into primary insurance products. The “primary insurer”
is deemed to be the product manufacturer under these circumstances. We will
liaise on an individual basis to supply content for their IPID in relation to
the ARAG cover that has been embedded.
We continue to hope that the FCA will agree to a
transitional introductory period which will allow us to fully review all of our
offerings and create suitable IPIDs for all of those special profile customers.
In the meantime, we will be contacting our agents to supply suitable IPIDs very
soon.
And what about
employment tribunal fee refunds?
While the abolition of unfair employment tribunal fees is a
splendidly good thing, it was very disappointing to read that where settlements
have been reached between the parties in dispute -with fees being included
within the settlement figure, the employer will be unable to apply for a
rebate. The employee, who would have paid the fee the first place (but recovered
it as part of their settlement), can apply for the refund and will stand to benefit
from a “windfall”. It seems that
employers who have “done the right thing” by settling the dispute are being
penalised, while those who may have proceeded to tribunal, lost and received an
order to pay will be able to obtain a refund.
This seems very unfair as escalating disputes to tribunal is surely a last resort. It is in the best interests of parties to arrive at an amicable settlement.
So, doing the “right” thing sometimes causes detriment however, we will always put our customers first. We remain committed to building products that work well and to raising customer awareness of the benefits they can access when they buy legal expenses cover.
