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Annual review of short-term policy essential

01 December 2008 | Non-life | General | Gareth Stokes

The latest FAIS Ombud determination is another victory for the consumer. In finding for the complainant, Anthony Naidoo against Absa Brokers (Pty) Ltd, Ombudsman Charles Pillai once again underlines the level of ongoing financial service required when ‘managing’ a client’s short-term insurance portfolio.

Setting the scene

The facts of the case are simple. In May 1999 Naidoo entered into a contract for short-term insurance with Absa Brokers as the intermediary. The policy was jointly underwritten by Mutual & Federal Insurance Company and Santam. Four years later, in July 2003, Naidoo added a new vehicle to this policy. His Toyota RunX RSI was valued at R200 000 at the time. What followed is typical for a short-term insurance policy. In March 2004 and March 2005 Naidoo received renewal letters for the policy. Each renewal letter contained a paragraph which reads: “In your own interest it is necessary to update the sums insured at regular intervals to avoid the negative effects of underinsurance. The omission of regularly revising the value of insured property to take account of the increasing rate of inflation, VAT and the diminishing value of the rand is having an adverse effect on the adequacy of sums insured.” That seems sensible enough. But the question arises: “Who is responsible for updating the vehicle’s insured value?”

In this case the insured’s vehicle was kept on the policy at its original value. Naidoo continued paying monthly premiums on R200 000 through 2004 and 2005, despite having had the opportunity to ‘lower’ the insured value on the vehicle at the policy renewal date in each of these years.

A moment of clarity

In February 2006 Naidoo contacted Absa Brokers with the view to adding another vehicle to his policy. During these discussions he realised that he was paying too much in premium for the Toyota RunX as the premium had never been adjusted for inflation. He instructed Absa Brokers to adjust the value, which they duly did. But Naidoo wasn’t prepared to leave the matter there.

He asked Absa Brokers three questions: First, why the vehicle remained insured for the original price from the date of purchase? Second, whether he qualified for any discount or reduction in the premiums already paid? And third, why the respondent didn’t alert him to such discount or reduction in premium? Their response was that “the onus of ensuring that the vehicle is insured for the correct yearly market value rests upon the complainant and not the respondent.” They also claimed that without full details of “accessories or modifications” to the vehicle they wouldn’t be able to determine a yearly value on the vehicle. This view was echoed by the insurance underwriters who referred the insured to the request to update insured values included with each renewal letter.

Unhappy with these responses, Naidoo then asked the underwriter why he shouldn’t receive a refund of the excessive premium paid between July 2003 and February 2006. When no response was forthcoming he took the case to the FAIS Ombud.

The insurance broker held to account

In their initial response to the complaint, Absa Brokers contend that the complainant “would have been duly informed of his obligations in terms of his policy, specifically with regard to ensuring that items insured under the policy were insured for the correct value.” They also maintained that the FAIS Act didn’t apply to this particular contract because it was taken out in 1999. The FAIS Ombud was unmoved by their defences.

He quickly dismissed the respondent’s attempts to escape the provisions in the FAIS Act. According to Pillai, “It is clear that upon renewal of the policy after the FAIS Act came into operation a new contract arose once again and the respondent had to comply with the Act’s provisions including the one that he must at all times act in the interests of the client.” Pillai also had some hash words for the insurer: “The insurers conduct, also does not inure to the principles of fairness, consumer protection or the integrity of the financial services industry. I am confident that the regulator will take appropriate steps to prevent this type of conduct occurring in the future.” The Ombudsman ordered Absa Brokers to pay the complainant R2 102.30, being the amount of excess premiums paid due to the vehicle value not being adjusted downward in 2005.

This determination outlines the level of service expected from financial service providers in the short-term insurance space. It’s not enough to simply forward an annual renewal letter to the client… Instead the broker should use this opportunity to communicate with the client, remind the client of the conditions on the short-term insurance policy and make sure the values on the client’s insured goods are correctly reflected on the policy schedule. Failure to do so is a failure to “render the financial service with due skill, care and diligence and in the interests of the client.”

Editor’s thoughts:
If you can learn anything from the latest FAIS Ombud determination it’s that you cannot ‘assume’ that your client knows anything – and you have to approach every aspect of your relationship on that basis. Explain the policy at date of inception and repeat every year until the client chooses to cancel it. Do you communicate with your client when his short-term insurance policy is up for renewal – or do you simply forward the policy renewal letter to the client? Send your comments to [email protected]

Comments

Added by Rene Bekker, 04 Dec 2008
I have only one question to the Ombudsman - What is the client's responsibility? As from the sound of it - the client does not have ANY responsibility towards updating his insurance - as if he has a broker; the broker becomes liable for everything! This is setting a false precedent - that a client has NO responsibility towards updating and maintaining his portfolio. And if the broker updates the vehicle retail value automatically - AND there is still bank finance oustanding more than the retail value? What then? Again the broker becomes liable! Why do pay for an FSB license - if the ombudsman rules against us all the time?
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Added by Chris , 03 Dec 2008
The entire insurance industry is becoming a laugh. On the one side, at the present rate, we are required to almost even BREATH for the client and on the other, the FSB and the Ombudsment are breathing down our necks to make sure we are following the law to BREATH for the client. I have always believed in providing clients with a service that is fair, honest and professional, and always in the interest, and to the benefit, of the client. The way the industry is going and the responsibilities that are being placed on us as brokers is becoming far-fetched. What is the purpose of informing a client of what his/her responsibilities are if that information comes to naught once it reaches the ombudsman? Whether I have informed a client of certain, specific decisions that are that client's resposibility and that provision of information does not hold up in court, because the client has not followed through with that advice, why inform the client in the first place - I, as broker, am going to lose out. PERIOD! As Karen wrote, "we're damned if we do and we're damned if we don't".
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Added by mark alcock, 03 Dec 2008
The learned Mr Pillai is quite right.This contentious issue has been allowed to prevail unfairly & unsquarely for far too long.A proper new system must be implemented ,either the insurers or brokers or both must prepare a system to calculate car values & accesories at all times. Possibly also request photos and have a computer system that revalues the cars at renewal , & or the broker must inspect himself or his clerks since the broker is earning comms & the insurer premiums.Alternatively ,the insurers should survey the cars on the insurers premises before insuring and renewing cover ,which Auto & Gen started too. compare ins to restaurants. If you eat out ,the menu spells out the food & price list ,there are no grey areas ,albeit sometimes the food is cold,undercooked ,over cooked or under-weighed & delivery time can oscillate unbearably too . As an ex short term broker, I am surprised ths car value problem remains problematic ,esp . with the Auto digest at hand , yet still a perennial problem.
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Added by Eddie , 02 Dec 2008
We have read the article written by Neesa Moodley-Isaacs in the Personal Finace dated 29 November 2008 and the article above. No matter what anybody says, we as brokers seem to carry all the risk in decision making. As per Karen's comments above, we are judged on the advice or lack of advice. The client never seems to be held liable for anything or any dicision they make. One thing that we as brokers must clarify with all insurance companies, is "what do they pay the client if their vehicle is totally destroyed in an accident or stolen?" We insure all our client's vehicles for the retail value as this is what it would cost to replace one and NOT market value. Market value has too many variables to be able to give an accurate value. Therefore, may advice to all my fellow collegues - insure for retail value and DO NOT let an insurance company tell you otherwise. We have done this for the past 18 years and NEVER has an insurance company paid out less! We as brokers need to stand together and dictate certain terms and conditions to ensure our survival and that of the client who wants professional advice.
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Added by Louise, 02 Dec 2008
Many short-term insurance policy wordings state "VESA Approved anti-theft device" applicable for vehicle theft cover. This requirement means that a VESA Certificate was issued upon inspection of the vehicle which confirms the existence of the vehicle, the content/extras, the condition of the vehicle and ultimately the quality installation of an approved anti-theft device. At time of lodging a vehicle theft claim, the Insured might then not produce a VESA Certificate, as he/she was not informed of handing in proof (in the form of the VESA Certificate) of the vehicle security device. A collective effort between the Underwriter, Broker and Installers needs to increase to educate the Consumer about obtaining the correct products and services as per the policy wording, it cannot only be left up to the Brokers.
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Added by Michelle, 01 Dec 2008
I think this is ridiculous. Although I do this every year for my clients I think it is about time the clients start taking some responsibility instead of blaming everyone else. Shortly we will be responsible for making sure their vehicles are services too!
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Added by Koos, 01 Dec 2008
So , what do you do? I normally revalue my clients vehicles, but now you have to tell him first before you revalue the vehicle and reduce the insured value?
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Added by Elna, 01 Dec 2008
Gareth, we indeed communicate with our clients at each renewal and point our several factors to them in the renewal letter with a summary of their current insurance since we know that most clients do not read the actual policy document. We suggest several aspects as to amend their policies to meet their needs, we also look up the car values using M&M and suggest the current retail values, we then prompt the client to give us permission to change the values for them and to advise us of any extras, their need for top-up and car hire etc. However we do not automatically adjust values since we had past events where vehicle values fluctuated in 3 months and some vehicle values went up and not down and when such a vehicle was written off, the assessor appointed by the company advised our client that their insurance broker under-insured them. Furthermore clients do sometimes add expensive extras to their vehicles after purchase and we are not always informed of this. We therefore do insist that the client give us written permission following our renewal notice to adjust values after making our suggestions.
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Added by Karen, 01 Dec 2008
I automatically adjust vehicle values for my clients on an annual basis. For those where we do not have a full list of accessories, we use a 10% contingency above the M&M retail value. However, I feel this determination works against the broker, once again laying all responsiblity at our door. Why did this client not query his values in that two year period? Everyone is aware of the fact that vehicle values depreciate! What if this broker had adjusted the value down, and there had been accessories that they were unaware of, or the condition of the vehicle was excellent, and upon submission of a claim it was found that the sum insured was inadequate? Would the client then have laid a complaint saying the Broker wasn't authorised to do this? Catch 22 situation - damned if we do, and damned if we don't!
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Added by Mike, 01 Dec 2008
Dead serious! I hear there is talk of legislation being passed which will force Brokers to hyphenate all multi-syllable words in their written correspondence to clients. The story circulating that the nanny state wants to reclassify the population as plant life is apparently just a malicious, pre-election rumour.
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