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The general insurance industry is hugely important to the UK economy.

The sector has been getting a lot of media scrutiny of late, in particular around some of the issues as a result of COVID-19 for example travel insurance and business interruption policies. Customers will want to know that they can trust their insurance provider, that they are receiving a fair price and they are not being penalised for their loyalty.

Firms are also awaiting the FCA's pricing market study report - due by the end of this year or start of 2021, - it is of no surprise that this topic is high on the agenda for firms given the regulators' increased focus in this area.

John Withington, former Senior Ombudsman and associate of Huntswood joins Nikki Ceko, Huntswood’s General Insurance Account Director and Paul Dyer, Huntswood's Head of Regulatory Risk and Assurance, to discuss the anticipated FCA market study. Discussion centres around the possibility there may be certain elements that firms will be reluctant to change because of a direct financial impact on the business or an impact on their competitiveness. Are firms waiting for the FCA to instruct the industry to move as a whole or should individual firms be proactive, if so, what should they be doing right now?

Our expert insight keeps you up to date on the latest industry developments and regulatory changes. Providing the guidance needed to drive better outcomes for your business and your customers.

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Nikki Ceko:

Hello, and welcome to this Huntswood Podcast. Today we're going to be talking about the general insurance sector on the topic of pricing and value, and really delve into some of the issues firms are facing when navigating this very complex issue. It won't be a surprise that pricing is high on the agenda for firms given the regulators' increased focus on the topic. And I think it's fair to say that we're all waiting with bated breath the FCA's pricing market study report, which is due at some point this year, or even early next. My name's Nikki Ceko, I'm the general insurance account director at Huntswood, and today, to look at some of the areas of this very wide reaching topic, I'm pleased to be joined by John Withington, a former senior ombudsman and an associate of Huntswood, and Paul Dyer, Huntswood's head of regulatory risk and assurance.

Nikki Ceko:

The general insurance industry is hugely important to the UK economy and is getting a lot of media scrutiny lately, in particular around some of the issues that COVID-19 has caused in areas such as travel insurance and business interruption. So customers will understandably want to know that they can trust their insurance provider and know that they're receiving a fair price and not being penalized for their loyalty. So I would firstly like to kick off by asking Paul; Paul, where is the FCA's main focus with regards to pricing fairness and value in the insurance industry and what should firms be doing right now?

Paul Dyer:

Great question to start with, thanks Nikki. Okay, so I guess it's been an interesting year for everybody really, whether you're a consumer, an insurer, or a regulator. And looking at it, I think regulatory priorities have taken somewhat of a dramatic shift during this period. So from what was some very aggressive regulatory practices, particularly on this topic over the last two years, I think they've taken a slight backseat during the pandemic in order to make sure that there was continuity of service, products, policies, and coverage in these unprecedented times.

Paul Dyer:

I think that created sort of a temporary distraction one way or another that now we're resuming full service with. And that full service really is driving towards the final report that's due at the end of this year from the FCA on pricing practices, it follows up on the interim market study from last year, the ABI/BIBA guidance from the year before, "Dear CEO" letter. I mean, numerous publications around product value, as well as some of the pandemic related changes in relation to temporary vulnerabilities and where some consumers are going through financial difficulty. So it's really back to full service now, we're expecting a report later in the year.

Paul Dyer:

I think the key step for firms is understanding really what are the desired outcomes they want for their customers and using this as a basis for business decisions. I can see a lot of firms taking actions, setting up programs, doing stress testing, scenario analysis of what exists, but a critical part of that is thinking about, well actually, how do they want to interact with their customers? Where is the value in their products? There's a bit of a trap. You could treat it as a tactical issue when really what we're looking at here is getting the balance right for the long term. So pricing fairness is very much front and center for the FCA. This isn't going to suddenly disappear, this is a longer term, slow burn focus. The key thing is, is making sure that firms are putting in place the needed programs to make the changes.

Nikki Ceko:

And John, I think it's fair to say that some of the early changes we saw with regards to pricing complaints were with the Financial Ombudsman, and as a former senior ombudsman who specialized in the general insurance and pricing complaints area, are you able to share what your experiences were during that time and any insight that you have?

John Withington:

Yeah, for sure Nikki. I left the service in February and was there for around six years, and much of my work, I'd say probably the last four years, I'd been very much specializing on looking into unfairness in the area of pricing and insurance, so relatively slow burn if I'm honest. But it really started when we noticed increasing concerns from consumers about renewal pricing. And although this scenario wasn't exclusive, it was often a sort of mom and dad's situation where you might have an older, grown up, son or daughter who had got their own insurance, had their own life and would find themselves having a conversation with mom or dad and often be shocked to hear some of the premium prices that were being paid. And we're talking here about often in the very high hundreds and not infrequently over a thousand pounds.

John Withington:

And actually when this is first was looking at property insurance, we were talking about fairly mundane, fairly ordinary insurance needs, nothing specific or special that would generate the need for such high premiums. And so we started to get more of these complaints and actually some quite passionate ones; older people, a son or daughter representing them coming to us. And that led us to start focusing on what the drivers were behind such high prices. And it became kind of fairly obvious to us that it was probably the impact of gradual price increase since the real increase in the market of the influence of price comparison websites, for example. And the prices had gradually got to the point where you couldn't ignore them anymore on renewal letters, they became quite surprisingly high.

John Withington:

I think many realized the challenges in this area, because obviously we aren't involved in price regulation and insurance services, there's a wide open market and often we would get the response from the insurers themselves when we asked these questions, that it was open to them to charge what they thought was appropriate and of course consumers could go elsewhere if they weren't satisfied. And that's absolutely right, with the essence of a free market where consumer choice exists. But while the insurers have hesitated often to even engage with us around pricing, feeling that it wasn't something for us, it was a commercial discretion issue, we found actually that they were always talking about things like underwriting. And when we came to look closer at some of these very high number insurance premiums, we weren't really being very persuaded that the underwriting factors were fundamental and that made major changes.

John Withington:

What became really obvious, and if I'm honest, insurers weren't comfortable, I think, talking about this, is that there were a lot of wider economic factors coming into play, particularly around consumer behaviour, around price tolerance ultimately. And those were clearly things that were necessary to fit with an economic model which was looking at price incentives for people entering the market, so lower prices, and offsetting some of those issues later on. So you're starting to see probably quite very common price management issues, but in an environment, obviously a regulated environment, where we're fairness for customers should be a key issue.

John Withington:

So we were concerned at that point about consumer fairness in the same way that the latest super complaint from the COB and the FCA's responses have been concerned. We started some discussions at that point with insurers who had the largest volume of complaints with us. There were a few that were very much towards the top end in terms of numbers of dissatisfied customers, and we started having formal conversations with those insurers about settlements. Our position was very much, and I believe that it remains the case with the Ombudsman Service, that when a consumer had an insurance policy for a number of years, we'd often find it would be three years or more, five years or more, where introductory discounts may have gone, they may have been clawed back, that we were looking that if there wasn't a very reasonable explainable reason for an increase, what we might think of as price drift, so gradual and substantial increase in price over a period of time, then we would look to see whether that was actually unfair.

John Withington:

And just to be very clear, it's really important to make this point, the Ombudsman Service is at no stage trying to say to businesses, "This is the right price for insurance". It's entirely up to an insurer how they treat underwriting, they can be entirely non-competitive and that wouldn't attract the interest of the Ombudsman from a fairness perspective. If an insurer wants to be non-competitive with its underwriting approach, then so long as it's doing the same thing for its consumers across the piece, and that's it, treating its consumers fairly.

John Withington:

So this isn't about what the right price is for insurance, it's about what the rationale is for increases in price. And where an insurer wasn't able to explain to us that there was a policy in place, a procedure, an underwriting approach, an attitude to risk, or specific issues about that consumer that led to their premium increasing because of let's say claims, then we were left with the conclusion that there was unfairness in place. And we actually negotiated with a lot of those businesses, we started to negotiate repayments of what we felt were overpaid premiums, so that was a fundamental step for us to take.

John Withington:

But actually I would emphasize something which I think a lot of people have overlooked, is that the whole business of pricing, there's something of an industry within insurance companies, there's a lot of issues around insurance premiums that aren't just about renewal. They're not just about what we started to call inertia and some people call price drift. There's lots of things about how insurers conduct the whole premium engagement with the consumers, where we would get complaints. And in fact, many more complaints would come to us about other issues than would come to us about inertia. So we would get complaints about things like midterm adjustments, things like nondisclosure issues, even things like refunds of premiums because of mistakes. And we actually set up a unit that I led for two years that looked at all of these scenarios and ended up concluding something like around 15 or 16 principles of fairness for all different types of scenarios of complaints, where there were still areas of unfairness in place.

John Withington:

What I think it said to us and said to me specifically, I think is that there is something of a... This isn't just, as Paul said at the start of this, an issue around changing some procedures around minor changes to the way in which pricing is set, for example, specifically about inertia. It's about a lot of ways in which insurers treat the customer pricing journey, how they take contribution, how they take premiums, how they recover them, how they adjust premiums, particularly as I said, during the life of an insurance policy, and many of those issues need to be unpicked as well as the large one at the moment, which is the one about inertia.

Paul Dyer:

It's really John, I mean, I think you hit the nail on the head really succinctly, when I think about it, the fact that you've got customers complaining that are then giving you these insights into that whole product governance and customer journey. And I think it's really easy to try and pick out the specific issues and deal with them on that tactical issue by issue basis. But fundamentally this is about trying to continually improve through product governance and customer journey, right? Listening to what it's telling you, looking at where things are going wrong, could be from a commercial customer regulatory standpoint and just making sure you're continually improving your practices to deliver better customer outcomes.

Paul Dyer:

I think to that extent, it's quite easy to almost get distracted by any one of the... Whether it's an inertia pricing, whether it's the idea of the renewal or dual pricing, there are a number of areas which demonstrate vulnerabilities and maybe where even consumer vulnerability isn't properly taken into account, but fundamentally are just indicators of where product governance needs to be better listening to the experiences actually of those involved in the process. It must have been very satisfying for you at the ombudsman, I think to probably get that broader view. I would've thought.

John Withington:

Yeah, I think that's right, what you said. And satisfying, yes. We certainly had a very different approach to complaints about pricing four or five years ago, where we were a little unclear and a little uncomfortable probably about stepping into this sort of area. We tended to deal with complaints which were about mistakes; a mistake in a premium being set because there was a record of a claim that didn't exist and so it was very easy to deal with those as being unfair and ask for the money to be returned. But actually unpicking some of the issues around the way in which this sort of macro-economic modelling filters through the whole process of how claim handlers, how premium handlers, how those dealing with administrative issues during the life of the policy, how they're interacting with consumers.

John Withington:

Simple things like, and I mean there will be cultural things like what we called worst case scenario assumptions. When it comes to lack of information about a consumer, it wasn't unusual to find an insurer take the worst case scenario to contribute to the underwriting. So let's say there was a new postcode which didn't have any risk record; a lot of insurers would take their highest flood risk rating and apply it to that because it was unknown. And we started to challenge and say, "Well, perhaps you should be applying the nearest postcode's rating rather than the worst case scenario".

John Withington:

And that applied similarly in cases to do with sizes of property, where if an insurer didn't know, there was an occasion we found that they put all of those where they lacked information to a hundred rooms, the maximum that the computer would take. Now that has an effect on premiums, but isn't necessarily the fairest way to treat a consumer, it's an administrative convenience and possibly, as you've touched upon, links into a general culture, which is trying to facilitate the hungry beast at the front end with low price of entry and having to have a sort of culture and policies that ensure that where the money is available, the maximum amount is recovered for other reasons elsewhere. So I think there's... Very satisfying to get to unpick some of that, but as you've pointed out, an awful lot I think for insurers to have to think about and a lot of work to be done on both procedures and culture as they try to unpick some of these issues.

Paul Dyer:

Yeah. I think the fact this happens to coincide as well at a time when the FCA is increasing its... We know it has a harm based model where it looks to identify what are the poor suboptimal outcomes for consumers, and it's gearing its decision making behind that, so it's turning to things like vulnerability much more. And they've linked very clearly to this issue I think, saying that where insurers don't address issues in equality of knowledge or help more vulnerable consumers, they're going to be taking very decisive action.

Paul Dyer:

I think this has attracted a lot of attention and I think for most firms, they're probably at the center of a dilemma around customer engagement, commercial performance, and then the scrutiny and the push from the regulator. How did you find, in terms of the complaints that you saw and you were involved with, how did you find the insurers were reacting to the complaints they were receiving from consumers? Was there any consistency?

John Withington:

I think if there was a consistency, it was very much that it wasn't an area that they felt the ombudsman should consider or should get involved in. And as I said, I think that at the start, that in an open market where people are free to choose, they felt that so long as they gave people the information through renewal notices, for example, that they required to by the regulator, including the last year's price, that they were doing their bit. And if consumers chose not to exercise their right to go elsewhere, then, and as I said at the start, the term often used is, "The price is the price". That became the mantra.

John Withington:

So initially and I think throughout, the way in which businesses tended to deal with the consumers at first point of contact, there wasn't an appetite for understanding or grasping the idea that there may have been some unfairness because of these larger economic models going on. So certainly we didn't see much willingness to go there and obviously I think that will be a real challenge as the regulator has made it very clear, the direction of travel, it will be a real challenge for many to have to face up to this and to make the changes we've talked about.

Paul Dyer:

In many cases it seems that firms, just as you're alluding to, are sort of now redefining what value is in this context. I think in terms of pricing, definitely from a consumer standpoint, we know that's one of the key indicators, you've got retail versus technical pricing and things that need to be taken into account. But there are other dimensions as well, such as the value the product gives, service and accessibility, thinking particularly to vulnerability, and experience more broadly, which I think is maybe over the years, insurance, particularly with competition, perhaps in some cases it's easy to lose track of any one of those in pursuit of another one.

Paul Dyer:

So I think for me to see complaints suddenly driving... and particularly the Financial Ombudsman Service with the super complaint and other things, sort of using what you're hearing to then drive better outcomes, I think that has to be a way forward. And I think for many of the insurers that we engage with, they're very open to this, it's more a case of just trying to work out how they almost reframe their activities to look at this through the new lens.

John Withington:

I'm sure that's the case. And I think the answer's in what you said there, is those you're working with. Those, I think you've probably engaged with Huntswood and are looking progressively at how they can provide better service and better meet obligations of the regulator and the clients, by definition of partway down the path already, aren't they. Of course, there's a lot of businesses out there that aren't actively engaged and will be reactive to the regulator. I think the real challenge to the market is how those position themselves and just how deeply they can grasp some of the cultural issues here and address them.

Nikki Ceko:

So I think Paul and John, we've seen quite a lot of activity from insurance firms already in terms of looking at their pricing strategies, looking at their product governance, et cetera. But there are certain elements of the market study that maybe firms are reluctant to change, just because of the impact maybe financially, or to their competitiveness, such as for example, the renewal pricing piece, the auto switching of customers onto better deals, very much waiting for the FCA to instruct the industry to move as a whole, rather than for individual firms to do it proactively. Is that your experience as well in terms of what you're seeing firms doing?

Paul Dyer:

I think it is. I think firms probably fall into a couple categories. You've got those who are dealing with the tactical issue at hand, you've got those who are adopting a much broader, a more root and branch review of what product value is. And then you've got some firms I think, who maybe have their head in the sand waiting to see where all this is really going to go.

Paul Dyer:

I think that in order to get on the front foot, there's probably a couple of key areas; one is around strategy, just aligning the pricing strategy with overall strategy, what you want to do for your customer, what value for money means for you, how this aligns to conduct risk. There's a piece then around risk assessment, understanding the regulatory environment and where your appetite is, assessing the degree to which your pricing strategy is being implemented in practice, the exposure within your risk models. And then finally, I think control environment, which is really about making sure the control and MR you have in place is making sure that at a minimum, your actions aren't exacerbating the problem.

Paul Dyer:

So there are some fundamental things that a lot of firms seem to be tackling, I think, in the right way. But there's definitely more to be done and I think waiting for the FCA to dictate the pace maybe could work out to be a folly, ultimately. John I'd be interested in terms of your experiences when looking at value in some of these complaints, value, I think, becomes quite a contentious term and maybe this is the root of the different responses we're seeing, did you have much interaction on the topic of what better value should be, or is with firms?

John Withington:

I had some interesting interaction, unrelated to pricing specifically actually, I went to some conferences which were dealing with, with claims. And I think a lot of firms would possibly argue that they have changed some of their marketing. I've seen this just as a general consumer looking at when you see your advertisements on the television, there's a lot more marketing now about value of claims handling, about walking people through claims, being more supportive. And that was presented to me when I went to a claims based insurance conference where I was illustrating some of the issues around value, true value of products, because of the breakdown in handling with the whole claims infrastructure, sending people off to different companies to different parts of the claims handling. And I was hearing from industry there very much a focus on trying to change, as I say, I think I've seen some of that in terms of advertising and marketing and the way in which customers are trying to be brought in now.

John Withington:

As you say though, there's a fundamental clash between some of those issues about value of a product if you still have in place the infrastructure that you put in place as an insurer to generate premiums, to meet your model, which was very much about front end cheaper prices and perhaps backend, and people are sometimes taking advantage of consumers and their inertia and their lack of information. So in terms of value of service, I've certainly seen plenty from industry and a lot of conversation around that, but typically that's been around claims handling. It doesn't tend to correlate and certainly never correlated in my conversation when we started talking about the price they were charging for things. It may well be that the reason for that is we were talking to people about price because we had concerns about their price methodology.

John Withington:

If industry can continue with that focus and wants to move towards pure true value, then we may see a more cohesive move and a more supportive move when the regulator brings in the requirements it will around pricing. But again, as I said, I've seen sufficient evidence to suggest that it's going to be a very large challenge for a lot of the insurers. I would say we used to have conversations certainly around pricing on the issue of price of production, as it was often referred to, and the idea that there's a price for insurance and that price has a median point which is somewhere based around the cost of administrating and then obviously servicing those claims.

John Withington:

But I saw plenty of evidence, including from some very large insurers when we were talking about the policy approach to this, of a real detachment between the reality of that and the prices they were charging their consumers and very difficult for them to correlate the idea that there was this price for production and where they were delivering that across their consumer base. What very much seemed to be the case is, as an average, they were delivering it, but some were winners as we're obviously aware of and talked about, and some were losers. And the losers were those, often, as you touched upon, who may be more vulnerable, maybe less liable and able to move.

John Withington:

And the example I gave earlier was a very general example, but it was very often the case that those complaints generated our concern. So, those years ago were older people whose grown up children were saying, "Mom, dad, why on earth are you paying this for your insurance?". So that begs a question about true value and about the way in which value is spread across the insured population rather than how it applies to each policy holder within the insurance portfolio.

Paul Dyer:

And I think there are two reflections there; one is that it was interesting in the interim report to see that the FCA had, despite hesitating previously I think, indicated that they may get involved in some sort of pricing model regulation. I think this reflects the extent to which there's concern with some of the pricing practices that are there, because this really is a Pandora's box for most regulators, getting involved in any sort of any sort of pricing model regulation. So that could be, even just the threat of that in the background could be game changing for the whole thing.

Paul Dyer:

The second reflection, just based on what you're saying, John, it'd be interesting getting Nikki's views here, is I think in terms of some of the complaints outlook work we're undertaking and engaging with firms, it's interesting to see the level of customer sentiment on these topics. I don't know if it's driven, and this is continuing, I don't know if it's driven by the fact that there is this vulnerability. I don't know if it's because actually this is more newsworthy than ever before and people are more aware of their rights, but the level of emotion that you see in some of the complaints that come through, it's almost moved beyond what is a simple pricing point issue. And I think it's challenging some complaints processes. What do you think Nikki?

Nikki Ceko:

Yeah, I would agree. And I think it was exacerbated even further by the recent events surrounding COVID-19 where you had some very difficult complaints being handled by complaint handlers working from home, who were dealing with people in very distressing situations who weren't necessarily getting their claim looked at in a timely manner, or indeed it being declined and therefore having to go through the complaints process. So I think that made some of the situations a lot worse.

Nikki Ceko:

I also think with regards to consumer behaviour, we've seen a bit of a shift recently and again, probably exacerbated by the COVID-19 situation, which is where customers are now seemingly going either straight to CEO letter complaints a lot more, and also in some cases going straight to the foz. So they're not going through the process either because there's a barrier in the way, if they can't get through to contact centres, or they can't navigate the online channel very well. And so they're doing the "Dear CEO" letter in terms of an executive complaint. I don't know if you've seen that as well, John, in terms of a shift of consumer behaviour?

John Withington:

Yeah, certainly that's the point you made, is the case, Nikki, is that people are more inclined to think now to get straight to the point and have more access to different points of entry for their complaint. I think though, that it's an interesting reflection that Paul made and one that I think I can probably shed a little light on as well, because as an ombudsman you deal with complaints about all sorts of things and you deal with complaints a lot about the claims process, which are fundamental moments in people's lives where something's gone terribly wrong. Their house has been flooded, they've been out the house for two years sometimes, there's been a mess up with the drying process, contractors have failed, et cetera. And there's obviously passion in those complaints when you come to deal with them, but actually I saw passion in complaints about pricing, which were just as powerful, in fact typically more so.

John Withington:

And some of that I think is about the very principles of trust. It's about the feeling that someone's been had over, if you like. When they'd realize after six or seven years that they've been paying an insurance price that when someone's pointed to an online price that's £700 cheaper, they feel thoroughly angry that they've been put through a process where they've left themselves with an institution that they may have some history with, but who they assume looks after their interests. And then to discover that actually they've had money taken away from them that they believe they've been, let's say conned out of, that's their personal perception. It generates a hell of a lot of heat and a lot of passions, as Paul said, which is at least as manifest, as I said, as you've seen some of these life changing incidents that people are dealing with about insurance claims and problems with the way in which the way their house is being rebuilt, for example.

John Withington:

So I think that whole issue and ethos of trust really gets to people and really creates heat, and as you say, with the ability of people to get more speedily to the point of contact, contacting directly and making noise that is heard louder through social media, through Facebook posts, through Twitter, that obviously generates speed and rapidity. But I think the passion is all about trust and about the sense that people have been taken advantage of.

Nikki Ceko:

I wanted to ask a final question because I'm always asked by insurance firms about it, so I guess Paul, it would be great to get your view on this, in terms of what potential remedies do you think the FCA will outline in their market study and what do you think firms could be doing right now in order to prepare for what the potential fallout from that might be?

Paul Dyer:

So I think there's three key areas really that we anticipate action; so restrictions on pricing practices, auto switching customers onto better deals I think, and auto renewals and transparency, are the three areas I expect to see changes, fundamental changes. I think beyond that though, the opportunity here really is, as John was kind of alluding to, is greater than the sum of the parts. So for those firms who are more proactive and go beyond what is expected reg change, actually there's an opportunity to build greater consumer trust and fundamentally take a competitive advantage. So I expect quite a broad set of changes, but what I'd like to see I think, is firms really taking this to heart and creating opportunity as a result.

Nikki Ceko:

Well, thank you very much. Paul and John, for providing your insight into how general insurance firms are preparing themselves for the upcoming FCA report. I think it's clear to see this a pivotal time for the industry and as good progress is made I think it's important that firms don't lose momentum. And I think it's also important to note the FCA's shift towards customer outcomes and value for money and it seems they may well be taking a bit more of an interventionist role in pricing. So whilst the focus of the FCA's investigation has been how pricing works within the GI market, there may well be implications for the whole of the financial services industry.

Nikki Ceko:

So please feel free to get in touch to carry on the conversation if this is a topic that's high on your agenda, or if you'd like to find out a bit more information and understand how Huntswood can support your firm, then please visit Huntswood.com, download one of our research papers and keep an eye on our social channels for further information on relevant topics, such as the pricing topic within regulated marketplaces.

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