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SA Home Loans wins its appeal

31 January 2008 | Compliance - Regulatory | FAIS Ombudsman | Gareth Stokes

One of the first stories we covered in 2007 (17 January) was the landmark case between SA Home Loans (Pty) Ltd and Saroja Naidoo. The FAIS Ombud Determination was published on 26 December 2006.

The facts of the case are fairly straightforward. Mr and Mrs Naidoo bought a bond protection plan from SA Home Loans Insurance to cover an additional bond taken over their fixed property. The policy was sold to them by direct telephone marketing. Mr Naidoo died six months after taking out the policy at which point SA Home Loans rejected Mrs Naidoo’s claim sighting a two year exclusion period on deaths caused by pre-existing conditions.

The original ruling centred on proper disclosure

Saroja Naidoo, widow of Subramoney Naidoo, complained to the FAIS Ombud in her capacity as the surviving spouse, and joint life insured under the policy. She claimed the details of the two year exclusion had not been properly explained to her – and that she would never have purchased the policy if they had been.

In his determination the FAIS Ombud stated:

“Clearly the disclosures relating to the exclusion was not properly communicated to Complainant [Mrs Naidoo]. Critically no communication was made to the deceased [Mr Naidoo] who, as the first Assured on the policy was a party to the contract. The disclosures made to the complainant were in any event, not provided in plain language, created uncertainty and was certainly not comprehensive enough. Additionally, it was confusing and misleading.

“It is clear that Complainant has and continues to suffer financial loss, as a result of the failure on the part of the Respondent [SA Home Loans] to render a financial service compliant with the FAIS Act.”

In summary, the determination in this case hinged on two key findings. The first was that SA Home Loans did not communicate important facts relating to the policy to both parties insured. The bond protection plan was a joint policy in which both Saroja and her husband’s lives were insured. The policy exclusion clause was only communicated to Saroja. And the second was SA Home Loans did not take proper care to ensure the key exclusion clause was clearly explained, brushing past the clause in a mere 14 seconds of telephone conversation.

Pre-existing condition not in question

Although the deceased’s death certificate lists ‘natural causes’ as the cause of death – the pre-existing condition was never in question. SA Home Loans introduce two witnesses in support of their appeal. The first, Dr Kayle, testified that Mr Naidoo suffered “from a cardiac condition dating back to 2003 for which he had been hospitalised several times.” The condition was made worse in that Mr Naidoo also had diabetes. Dr Kayle further stated that due to these conditions, the only insurance respondent’s husband could have obtained would have been what is called a “lean policy”. Such policies exclude death benefits (except accidental) for the first three to five years. This evidence was corroborated by Mr Hoffeldt, a senior underwriter.

This evidence was led to demonstrate that the Naidoo’s would not have been able to obtain another insurance product without a similar exclusion at the time. In other words, the respondents claim that had she known of the two year exclusion on the SA Home Loan policy she would have declined the policy and taken insurance with another would not have put here in a better financial position.

Determining the extent of the damage

The initial ruling ordered SA Home Loans to pay the outstanding indebtedness on the bond with effect from the date of death of the deceased, refund all bond instalments paid by the Saroja Naidoo since the date of death of the deceased until settlement of the claim and interest in the amount of 15.5% per annum on outstanding amounts. SA Home Loans also had to pay R1 000 to the Ombud’s office for case fees.

The appeals board subsequently determined that the FAIS Ombud had incorrectly assessed the financial loss suffered by the respondent. They ruled that the only loss incurred by Saroja Naidoo amounted to the insurance premiums the she (and her husband) had paid over on an insurance policy they (by her own admission) would not have taken out had proper advice been given.

The appeal was upheld and the order changed. SA Home Loans has been ordered to pay Saroja Naidoo half of R3 956.73, being her share of the insurance premiums paid. This is “equivalent to the share of the joint estate of her husband and herself to which she became entitled on the death of her husband. SA Home Loans will have to pay interest on this amount at 15.5% per annum from the date of the Ombudsman Determination on 21 December 2006. The R1 000 awarded to case fees is still in place.

Editor’s thoughts:
Half way through 2007 we carried another article on the case. At the time SA Home Loan’s right to appeal had been denied, prompting many to question whether the FAIS Ombud should have carte blanche to refuse cases he determined. SA Home Loans persisted – and this case proves that even when the facts of a case remain largely unaltered, the determination of damages can change significantly. Do you think the appeal ruling is fairer than FAIS Ombud Determination? Add your comments below, or send them to [email protected]

Comments

Added by rick, 31 May 2012
SA Homeloans are a bunch of thives . How do you people live with your families when you rob and steal fm honest hard working people .
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Added by nobose, 04 Feb 2008
i strongly disagree with telephone Marketing strategies, the consultants speak loudly when it comes to the insurance benefits and speak soft and fast when the talk about exclusion, telephone Marketings should be banned as and anyone who wants to take insurance to go get brouchers and then have a chance to call in after reading the policy and not the other way around
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Added by Plonkie, 02 Feb 2008
I concur with other respondents about the pitfalls of telphone marketing, but I am more interested to know how SA Home Loans convinced the appeals board to listen to them after it was reported that the Ombd refused an appeal??
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Added by Ocean, 01 Feb 2008
I personally detest the practice of "Telephone Life Assurance" I don't believe proper advice is given, and I am constantly harangued by these calls myself.
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Added by Corrie Benade, 01 Feb 2008
Telephone marketing on risk products is an evil thing that needs to be stopped. It is cases like this one with SA Home Loans, that creates a bad image of the financial industry and honest people earning an honest living by adding integrity to their work. As far as I am concerned, all telemarketing should be banned from the industry. SA Home Loans should be held liable for the loss of the client. You cannot do a proper FNA telephonically in a few minutes. And that is exactly what FAIS stands for, integrity, honesty, and enough information provided to the client to make an informed decision !!! BOTTOM LINE !!
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Added by FAM, 31 Jan 2008
I certainly agree with the appeal ruling for the simple reason that the insured did not disclose material facts which would have altered the Insurer acceptance of the risk. Should the claim have been met in full, it would have discriminated on those clients who had made full disclosures and were denied cover or had their premiums loaded. This should send a clear message on the importance of full disclosure and actually " level the playing field"
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Added by Armstrong Ndlela, 31 Jan 2008
I think the ruling was unfair, the the need for disclosures should apply both sides, Soroj Naidoo would have sought cover from other institutions had she known that they (SA HOMELOANS) does not cover pre-existing conditions.The fact that they were prepared pay for cover, means they would have sought other cover. The FAIS Ombudsman must discourage tele sales it always prejudice the consumer, they tend to oversell and not disclose properly.
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Added by Quinten Knox BLC LLB, 31 Jan 2008
. Hi everyone . I have not read the record of Appeal myself. . However, Ms Ndleda (above) misses the point. ----- Whether or not Ms Naidoo or the deceased would have sought cover elsewhere is not the point. ----- The point is that even had they sought insurance cover elsewhere they would not have obtained it (unless it was a "lean policy"). Therefore, no damages were incurred. ----- As to 'fairness' itself : can anyone describe sufficiently / define / provide a benchmark on what "fairness" is? I think not. ---- The Ombud's rules require that the Ombud when disposing of a complaint must act "independently and objectively" ----- To my mind those two concepts on their own or jointly are insufficient to constitute fairness. ----- At best they are two concepts that are included in "fairness". ---- Something else is required for fairness to be present. ------ An enquiry into the concept of fairness is a philosophical enquiry. ----- The FAIS Act also refers to "fairness". ------ how does determine whether a dispute has been disposed of fairly? How does one determine whether a dispute has been disposed of UNfairly? .
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Added by AM, 31 Jan 2008
ifficult to make a comment that is legally sound and/or viable. However, I agree with the ombudsman. If you watch the Virgin Mobile advert “The Truth will set you free” it thrashes at things like these, where you are only told about the good in acquiring a contract and all other things are omitted/ hidden from you. These sales people say so many things to you knowing that the anything things go wrong there won’t be recourse as they would claim they stated everything to you. If Home Loans sent a written contract (with fine prints obviously) following their telephonic communication to the couple, then they would have had a case as it is our (Clients’) responsibility to read/interpret and/or understand these fine prints. Lessons: Never believe anybody selling anything to you telephonically Make sure you read/understand the fine-print at the back of every contract you sign.
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Added by CL, 31 Jan 2008
I am pleased with the outcome in favour of SA Home Loans, not because I am partial towards them, but because it proves a point that the Ombud is not infallible. When we have a “TV umpire” why don’t we refer a decision to him. Those in positions of judgment are perceived to be reluctant to allow their decision to be questioned like cricket umpires. Perhaps this will set a president for future disputes where the Ombud’s decision has been regarded as the only form of conflict resolution. You will recall my response last year when the Ombud indicated that he was out to focus his attention upon the service providers and not the product providers. I still maintain he is biased.
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