Page 28 - Insurance Times July 2016
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down turnaround times for policyholder servicing in its regu-     carefully specifies the limits and what exactly are the roles
lations for protection of policyholders' interests brought out    and functions of each of the regulators.
in 2002 and these relate to right from the time before a
contract is entered into through to the point of all obliga-      There are differences in opinion between IRDA & SEBI about
tions under a contract being settled. Delays vis-a-vis these      what the SEBI remit is and what SEBI believes its own merit
timeframes would mean a deficiency in service. When there         is - may this turf war may go on but ultimately both are here
is a deficiency in service, the prospect or policyholder, as the  to ensure consumer satisfaction, investor protection and
case may be, may approach the grievance redress channel           financial stability. Things of this nature need definite clarity.
of the insurer and the IRDA, if needed to escalate the case;      Having multiple regulators doing the similar task would not
or the Ombudsman, if it falls within the jurisdiction of the      be good for the consumers or the industry. So there must
same.                                                             be sufficient initiative of IRDA to resolve all these
                                                                  disparities.
11) IRDAI'S directives to resolve com-
plaints against insurers & greivance                              We find that management expenses of all the insurers af-
dispossal:                                                        fect bottom lines more sharply, so IRDA intended to bring
                                                                  in various systems to enable and cajole insurance compa-
11.1. The initiative of IRDA in implementing the Integrated       nies and absolutely ensure that the insurers comply by look-
Grievance Management System (IGMS) has created a cen-             ing at extra solvency requirements. Moreover, as the Indian
tral repository of industry complaints, which lends itself to     insurance industry has already made a strong enough base
various types of analyses relating to conduct of business by      and going by the trend of the market - the days are very
insurers. The regulatory interventions by IRDA on ULIPs have      near when one of the biggest contributors to the Indian
brought down the percentage of complaints pertaining to           stock markets will be investment from the insurance
this category, reflecting an improvement in the conduct of        sector.
business in this area.
                                                                  So the regulator has to tighten their control in manifolds.
11.2. Prescription of a standard proposal form for life insur-    Broadly speaking investment by insurance companies is regu-
ance and the requirement that the insurers shall have in          lated by the provisions of the Insurance Act, with 50% of
place a "Prospect Product Matrix" that will determine suit-       investments going into government securities, 35% into
ability of products based on needs analysis is an initiative      approved investment and 15% being in other than approved
that will help reduce mis-selling.                                investments. There are other issues such as concentration
                                                                  and sector risks. From the regulatory point of view it has to
11.3. In non-life insurance, analysis of the data on IGMS         be typically ensured that the insurers must have in place
shows that 'Non-receipt of Policy Bond' is the main cause of      automated or efficient systems that can provide full range
complaint though complaints relating to claims come a close       of information.
second. Conduct of business concerns in this sector mostly
relate to health insurance and motor insurance - refusal to       To stop the general insurers' practice of giving discount
give cover; refusal to renew; forced selling through tying        without any concern for base level threshold premium,
insurance with other goods and services; disputes related         in the recent meeting in General Insurance Council, it has
to quantum of claim and disputes relating to liability under      been proposed that a minimum rate must be in place for all
a policy.                                                         classes of business in order to prevent mindless competition
                                                                  in de-tariffed non-life sector. Let us expect that IRDA
Conclusion:                                                       must keep these product minimum rates at a strong
                                                                  watch.
In the Indian regulatory system, process & architecture,
what different regulators will manage is specifically defined     Reference: References have been taken from the contem-
by law. Present system might not be the best system and is
not the only system in the world, but in India we have en-        porary text materials / various IRDA Reports / different
acted ourselves a system where each sector is separate. The       current discussions as read in hard & soft forms. 
scope of regulatory overlap is invariably limited as each Act

28 The Insurance Times, July 2016
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