Letter to CCIR re: revised Guideline G7Release Date: 06/29/2016 Staff Reference: Erica Hiemstra
June 29, 2016
Mr. Patrick Déry
Surintendant de l'encadrement de la solvabilité
Autorité des marchés financiers
Chair, Canadian Council of Insurance Regulators
2640 Laurier Boulevard, 6 étage
Quebec, Quebec G1V 5C1
Dear Mr. Déry,
I am writing on behalf of the Canadian Life and Health Insurance Association (CLHIA) to provide you with a copy of our recently revised Guideline G7, Creditor’s Group Insurance. The Guideline revisions were adopted by CLHIA’s Board of Directors at its last meeting and will take effect June 1, 2017.
Established in 1894, CLHIA is a voluntary non-profit association with member companies accounting for 99 per cent of Canada’s life and health insurance business.
Guideline G7, Creditor’s Group Insurance, protects the interests of debtors by promoting consistent practices for insurers and by providing operating and disclosure standards for the transaction of Creditor's Group Insurance. The current revisions were made to ensure that the standards set out in the Guideline take a customer-focused approach to distributing creditor's group insurance and incorporate international standards and Canadian regulatory expectations for insurance distribution.
The revisions include:
• Adding principles on treating customers fairly, clear disclosure, and insurer accountability. Although these concepts exist in the earlier version of the Guideline, they were not as crisp as they could be. Now they are explicitly stated in Section 3. General Principles.
• Strengthening disclosure during the application process to include information about the insurance coverage provided by the product (e.g. life insurance, disability insurance, critical illness insurance); eligibility requirements; and, under certain circumstances, the effect of financing changes on the insurance; in Sections 9 (6) (a) and (b) and (9) (7), respectively. These disclosures add to the existing disclosure standards to assist consumers in making an informed enrollment decision.
• Adding information on complaints to Sections 10 (3) (l) and 14 to ensure consumers have access to information on how to make a complaint about their insurance.
• Strengthening training requirements to include the insurer's complaint procedures and the potential impact of changes in the credit arrangements on any existing insurance, in Sections 11 (2) (g) and (c), respectively. These topics add to the relevant topics already covered in training programs.
• Adding Section 8. Change of Insurer, that reflects the standards set out in CLHIA Guideline G3, Group Life and Group Health Insurance. This is particularly relevant in circumstances where a consumer is "on claim" when the change takes place.
• Simplifying and clarifying the Guideline's language, where possible.
We note that the Guideline revisions were not subject to the customary review by CCIR’s Standards of Practice Committee, which is on hiatus, before being adopted by CLHIA’s Board. In the spirit of keeping our regulatory community informed of significant updates to industry oversight and disclosure standards, we are pleased to enclose a copy of the revised Guideline. Please feel free to share it with your CCIR colleagues.
Please contact me should you have any questions about the Guideline.