2012 General Insurance Code of Practice Aggregated Industry Data Report Overview of the Year

(1)

2012 General Insurance Code of Practice

Aggregated Industry Data Report

Overview of the Year 2013–2014

FOS Code Compliance and Monitoring Team

(2)

1 This Annual Report

Welcome to our Annual Report for the reporting year 2013–14. It reviews our work on aggregated industry data and consolidated analysis of Code compliance under the 2012 General Insurance Code of Practice (the 2012 Code). We have undertaken this work in collaboration with 156 general insurers and Lloyd’s Australia Limited coverholders and claims administrators from around Australia.

We have outlined information and aggregated industry data reported to us by Code

Participants (collectively called “the industry” for the purposes of this report) for the reporting year including:

 policies, claims, declined claims, withdrawn claims and internal disputes handled during 2013–14, and

 industry-identified non-compliant activity and remedial actions.

We have recorded Code Participants’ views on factors that may have influenced changes in the data since the previous reporting period. These considerations must be kept in mind when interpreting the data.

The report also shares our experience of good industry practice and the initiatives of Code Participants to improve standards of practice and service in 2013–14. Identifying, self-reporting and remedying non-compliant activity with any code of practice is critical for a successful regulatory framework. We have encouraged a positive culture of

self-reporting by Code Participants so that we can work with industry in a timely and responsive way to reduce risk and improve service delivery. We acknowledge the cooperation of Insurance Council of Australia (ICA) and Code Participants in this endeavour.

We have previously reported on the outcomes of our key Code monitoring activities for 2013–14, published in the appendices of the former Code Compliance Committee’s Annual Report for 2013–14. 1_{You may view the report by clicking here.}

This is the final time we will publish an Annual Report of this nature.2_{From 1 July 2015, the} new General Insurance Code Governance Committee will assume responsibility for

publishing all annual aggregated industry data results under the 2012 and 2014 Codes.

1_{See Schedule 2, Appendices, General Insurance Code of Practice, Annual Report of the Code Compliance Committee, 2013–}

14 available from www.codeofpractice.com.au.

2_{This Annual Report has been prepared by the Code Compliance and Monitoring Team, a separately funded business unit of}

(5)

2 About the 2012 General Insurance Code of Practice

The ICA launched its General Insurance Code of Practice (the Code) in July 2005 and it became operational on 18 July 2006. The 2012 version came into effect on 1 July 2012.3 The ICA released a revised Code — the General Insurance Code of Practice 2014 (the 2014 Code) — on 1 July 2014. Code Participants have 12 months to complete their transition to the 2014 Code which will become operational on 1 July 2015.

The 2012 Code covers service standards in several areas, broadly described in Diagram 1. Code Participants, their Employees, Authorised Representatives and Service Providers were required to comply with these standards during 2013–14.4

Diagram 1: The 2012 Code standards

The 2012 Code covers most general insurance products, which are broadly categorised in Diagram 2. It does not apply to workers compensation, marine insurance, medical indemnity insurance5_{, compulsory third party insurance, reinsurance, and life and health insurance}

products issued by life insurers or registered health insurers.6

Diagram 2: Classes of general insurance covered by the 2012 Code

3_{The new 2014 Code, the 2012 Code and earlier versions are available from www.codeofpractice.com.au.} 4_{The 2012 Code, sections 1.6 and 7.4.}

5 _{Medical Insurance Australia Pty Ltd, a medical indemnity insurer, has voluntarily adopted the Code.} 6 _{The 2012 Code, sections 1.4 and 1.5.}

Section 2 Buying Insurance Section 3 Insurance Claims Section 4 Responding to Catastrophes & Disasters Section 5 Information & Education Section 6 Complaints Handling Procedures Section 7 Code Monitoring & Enforcement

Accident & Sickness Consumer Credit Home

Motor

Personal & Domestic Property Residential Strata Travel Personal Classes Business

Contractors All Risks Farm

Industrial Special Risks Liability

Motor

Other Commercial

(6)

3 2013–14 Year at a glance

The general insurance (GI) industry experienced modest growth in 2013–14, with a small 7% increase in policy numbers and a corresponding 4% increase in claim numbers overall. Notably, industry reported moderate to significant increases in declined claims for Consumer Credit, Personal & Domestic Property, Residential Strata and Travel insurance products. Overall, the number of declined claims increased by 11%. At the same time, personal insurance disputes fell by 16% and personal insurance disputes about claims fell by 14%.

We have aggregated the industry data in Appendix B and discussed it in Parts 7 – 11 of this report. A summary of the data is presented here and we have also included a three-year overview of key industry data in Appendix C.

Employed 34,960 staff

In addition, Code Participants engaged the services of 5,367 corporate Authorised Representatives, 11,145 individual Authorised Representatives, and 11,651 agents and independent contractors.7

Trained 35,805 people in Code obligations This consisted of 18,175 employees, 9,363 individual Authorised Representatives and 8,267 agents and independent contractors.

Issued 45,816,250 GI policies  7%8

These policies consisted of 41,799,079 personal insurance policies (up 9%) and 4,017,171 commercial insurance policies (down 16%).

See page 12 for more 

Received 3,918,269 GI claims  4%

These comprised 3,410,691 personal insurance claims (up 5%) and 507,578 commercial insurance claims (down 6%).

Declined 110,298 GI claims  11%

These comprised 105,945 personal insurance claims (up 12%) and 4,353 commercial insurance claims (down 10%).

Withdrew 131,909 GI claims 24%

These comprised 127,865 personal insurance claims (down 26%) and 4,044 commercial insurance claims (up 114%).

Reported 27,077 internal disputes raised by consumers 15%

These consisted of 25,486 personal insurance internal disputes (down 16%) and 1,591 commercial insurance internal disputes.

Internally reviewed 27,566 disputes 13% This resulted in 19,905 outcomes in favour of Code Participants and 7,661 outcomes in favour of consumers.

Remedied 21 significant breaches

These breaches affected at least 19,236 consumers and resulted in the payment of $767,659 (including interest) to consumers.

Identified, remedied and reported 5,612 Code breaches  9%

Breaches were remedied in various ways, mainly through coaching or further training for employees and/or Authorised Representatives in processes and systems.

See pages 12, 17, 27, 29 and 30 for more 

7_{Agents and}_{/or independent contractors are individuals engaged in the distribution of a Code Participant’s products and other} services, but are not its Authorised Representatives.

(7)

4 Industry compliance initiatives

Individual Code Participants introduced several initiatives to improve Code monitoring and reporting frameworks in 2013–14. These have strengthened compliance risk assessment processes and further embedded compliance requirements within their businesses. We have summarised these initiatives in Table 3.

Table 3: Industry compliance initiatives in 2013–14

Compliance and risk reviews, reporting and analysis

Compliance and risk systems and processes Individual Code Participants:

 Employed risk teams to provide specialised technical support in risk reporting, data analysis and risk management.

 Conducted independent operational reviews to strengthen Code compliance.

 Distributed online compliance questionnaires to all Authorised Representatives to identify and address compliance gaps.

 Reviewed systems and processes to ensure they comply with requirements of the 2014 Code.  Appointed a compliance team to independently

review and monitor business operations.

 Engaged legal counsel to review the 2014 Code’s obligations and oversee complaints handling processes.

 Conducted monthly audits of each claims area to evaluate compliance.

Individual Code Participants:

 Continued to use internal and external auditing.  Created an online database to review Code

compliance in claims files; this included analysing trends, reporting on outcomes and tracking claims through to completion.

 Created new compliance-focused roles and teams covering customer service, quality assurance, risk management, compliance and coaching.

 Created risk operations and risk change teams to provide analytical and operational support and manage change.

 Developed formalised compliance frameworks.  Embedded Code monitoring within compliance

frameworks.

 Conducted internal and external reviews of their compliance framework, detailing compliance with relevant standards and requirements, and

recommendations for improvement.

 Reviewed and updated breach and compliance policies and procedures, internal documents and templates to ensure they comply with the 2014 Code.

Staff development and training Claims processing Individual Code Participants:

 Offered staff training via online modules and training packs on privacy and complaints handling, and provided training on the 2014 Code.

 Distributed complaints handling training packs to all customer service teams.

 Provided improved feedback on Code compliance issues to staff.

Individual Code Participants:

 Distributed a new daily claims monitoring report to claims staff detailing the status of each outstanding claim.

 Gained efficiencies in claims processing by allowing customers to lodge claims online.

 Introduced claim acknowledgement letters for policyholders, enabling them to review their claim and provide additional information.

 Redesigned the claims handling process to improve customer service by increasing communication channels to inform policyholders, clarifying staff roles and responsibilities, and taking a proactive approach to finalising claims.

(8)

5 Our key observations

Data trends in particular classes of personal insurance such as Consumer Credit, Personal & Domestic Property and Travel, suggest to us that there is a gap between consumer expectations and how these products operate in practice. Industry needs to more fully understand the factors that underlie these trends and address those that may act as a barrier to informed decision making and consumer understanding about the features of the cover held within these classes of personal insurance.

We will recommend to the General Insurance Code Governance Committee (GICGC) that it monitor these trends closely and report further in its 2014–15 Annual Report.

We note that during 2013–14 for example in relation to: 1. Consumer Credit insurance products and services:

 Industry declined 3,791 claims, up 19% while the number of claims in this class fell 9% to 26,237.

 Consumers lodged 426 internal disputes with industry about products and services overall, up 25% and 368 internal disputes were about claims, up 28%.  More than half of internal claims disputes concerned declined Consumer Credit

claims, with 202 internal disputes.

 There was also a 21% increase in withdrawn claims in this class. 2. Personal & Domestic Property insurance products and services:

 Claims increased 23% to 441,116 and declined claims increased 72% to 32,930.  At the same time consumers lodged 957 internal disputes about products and

services overall, up 23%, including 786 internal disputes about claims, up 15%.  Of the 786 internal claims disputes, 624 internal disputes were about a decision

to decline a claim.

3. Travel insurance products and services:

 The overall number of internal disputes about products and services increased 15% to 2,399.

 Internal disputes about claims increased 40% to 2,334 and included 1,849 internal disputes about a decision to decline a claim.

 At the same time Code Participants declined 24,271 claims, up 21%.

Buying insurance

Industry reported 604 instances of non-compliance with obligations related to fairness and transparency in the buying and selling of insurance products to consumers in 2013–14. Most of these instances were due to employees or Authorised Representatives not following existing organisational procedures.

(9)

We recommend industry remain vigilant about compliance with these key obligations to ensure that consumers are dealt with appropriately and fairly when buying or renewing insurance products. We also encourage industry to foster a culture where organisational procedures are consistently applied in service delivery.

Insurance claims

Industry self-reported 3,835 breaches of the Code’s claim handling standards in 2013–14, representing 68% of all industry-identified non-compliant activity. The timeliness, fairness and transparency of claims handling processes and consumer access to key information about their rights when a claim has been declined are extremely important. The data suggests that industry performance in these areas needs to improve.

Withdrawn claims

We encourage Code Participants to record and report withdrawn claims data and reasons for withdrawal. Whilst the number of Code Participants who are able to report this type of information is growing (up from 61 to 71), some Code Participants are still unable to do so. Further, we are concerned that the withdrawn claims data received for 2013–14 is not as robust as it could be and seems to have been affected by systems limitations and other factors such as migration of data from old to new systems, or systems incompatibility. Despite more Code Participants reporting withdrawn claims data in 2013–14, the number of reported withdrawn claims overall fell 24%. As a result, data about withdrawn claims in this report should be treated as indicative only.

We believe that consistent and accurate recording of data and information about withdrawn claims is important and may further assist insurers to:

 Ensure that consumers have made informed decisions and that they understand the impact withdrawn claims may have on future claims or premiums, especially consumers’ no claim bonus (NCB) entitlements.

 Determine whether the incidence of withdrawn claims is influenced by product design and/or features or the way in which those particular products are sold to consumers. We note that the advice from industry that the obligation not to discourage consumers from lodging claims (section 3.4.3) may be a factor contributing to the incidence of withdrawn claims (and declined claims) seen in some classes of personal insurance. We suggest however that this reiterates our view of the importance of withdrawn claims data and the role it plays in understanding consumer behaviour.

(10)

6 How to read this report

This report analyses two sets of data provided by industry:

 Aggregated industry data about policies, claims, declined claims, withdrawn claims, internal disputes and their outcomes across personal classes of insurance namely, Accident & Sickness, Consumer Credit, Home, Motor, Personal & Domestic Property, Residential Strata and Travel.

We have provided a consolidation of the data in Appendix B, a three-year industry overview in Appendix C and further data in Appendices E to L.

 Aggregated industry-identified breach data which we have also summarised in Appendix D.

To assist you to read this report we have provided a glossary of terms in Appendix M. The data and information has been described in this report under the following headings:  Buying insurance – Part 7

 Claims, declined claims and withdrawn claims – Part 8  Financial hardship – Part 9

 Responding to catastrophes and disasters – Part 10, and  Internal disputes – Part 11.

We have decided to focus attention on retail insurance products in this report. This is because:

 the primary focus of the 2014 Code is retail insurance products, and

 industry is currently transitioning to the 2014 Code and must be compliant by 30 June 2015.

If you have a particular interest in the commercial data it is presented separately in Appendices B and Appendices E to L.

We rely on Code Participants to:

 carefully review the data they submit to us to ensure its accuracy

 consult with us about data trends and explain the factors that may have influenced the data year on year, and

 let us know if there are any errors in previously submitted data.

This is to ensure that the aggregated data published by us – and in future by the GICGC – is as accurate as possible and that data trends can be explained, either at an individual

company or industry level. We do not independently audit the data submitted by Code Participants.

(11)

We note that variation in the data reported to us by industry occurs for a number of reasons including differing reporting frameworks from company to company. As a result, when reading this report please treat the data as conservative in nature and indicative only of current trends.

For example, we note that nine Code Participants identified under-reporting errors in some of their 2012–13 data for Accident & Sickness, Consumer Credit, Motor and Personal & Domestic Property insurance products. We have amended the relevant 2012–13 data and all comparative data in this report is based on that amended data.

We intend to consult further with industry and the GICGC to build a more consistent and robust reporting framework into the future.

(12)

7 Buying insurance

Industry overview

The overall number of general insurance policies issued or renewed in 2013–14 is presented in Table 4. The data shows that policy numbers increased slightly overall.

Table 4: Personal and commercial general insurance classes – overview of policy numbers in 2013– 14 and variation against 2012–13 data

Industry trends

The top three classes of personal insurance products bought by consumers from Code Participants in 2013–14 were:

 Motor: 13,274,831 policies, accounting for nearly one third (32%) of all personal insurance policies issued/renewed in 2013–14. Motor includes products such as comprehensive motor vehicle cover and third party property damage.

 Home: 10,901,783 policies, comprising 26% of personal insurance products acquired by consumers. This category consists of cover for home buildings, contents, combined building and contents and residential landlord.

 Travel policies increased 43% to 7,392,489 policies (18% of personal insurance products). Code Participants have reported that the growth of Travel may have been due to factors such as the:

o Capturing of individuals covered by group policies.

o Capturing of policies that were previously excluded because premium was not payable.

o Commencement of new product distribution arrangements.

o Restructuring of other types of insurance products which resulted in their allocation to Travel.

The data is presented in Table 5 and also shows that:

 Accident & Sickness policy numbers increased 135%. Code Participants have attributed the increase to the ability to identify individuals covered by group policies and allocation of restructured products previously in other classes.

 Personal & Domestic Property policy numbers have remained steady. It is the fourth largest class of personal insurance products and accounted for 15% of all personal

Personal Classes of General Insurance

Commercial Classes of General Insurance

All Classes of General Insurance

Number of policies 41,799,079 4,017,171 45,816,250 % variation from

2012–13

(13)

insurance products issued during 2013–14. This class includes products that provide cover for a diverse range of items ranging from pets to pleasure craft.

Table 5: Personal classes of general insurance – number of policies in 2012–13 and 2013–14

Industry compliance data

Section 2 of the 2012 Code applies to the way in which Code Participants, their Employees and Authorised Representatives sell and renew insurance policies, and respond to

consumer enquiries about insurance products.

We expected that industry would continue to improve its ability to comply with fairness and transparency obligations in the buying and selling of insurance products during the reporting year. In 2013–14 industry identified and remedied 604 breaches of section 2, accounting for 11% of all non-compliant activity including:

 153 breaches of industry’s obligation to conduct sales processes in a fair, honest and transparent manner (section 2.1.4).

 164 breaches of industry’s obligation to ensure that employees and Authorised Representatives conducted their services honestly, efficiently, fairly and transparently (section 2.4.1).

Most of these instances occurred because employees or Authorised Representatives did not follow procedures established by Code Participants to ensure compliance with their Code obligations. 13,274,831 10,901,783 7,392,489 6,481,045 2,560,921 1,042,586 145,424 13,354,030 10,675,952 5,172,203 6,689,125 1,087,968 1,066,956 174,457 0 5,000,000 10,000,000 15,000,000 Motor Home Travel Personal & Domestic Property

Accident & Sickness Consumer Credit Residential Strata Number of Policies Pers o n al In su ra n ce C la ss es Policies 2012-13 Policies 2013-14

(14)

Here are seven examples of how that non-compliance occurred.

Code Participants that actively monitor compliance with their fairness and transparency obligations will be better placed to ensure that they deal with consumers appropriately and fairly when buying or renewing insurance products.

Industry is also encouraged to remind employees and Authorised Representatives of the importance of adhering to procedures which enable industry to fulfil its compliance obligations.

Examples of non-compliance with standards that apply to buying insurance

1. Some employees did not adhere to sales scripts that they were required to use when offering insurance products to consumers under a No Advice Model. A Code Participant identified this issue for example, during regular monitoring of sales staff by team leaders and its quality assurance team 2. Consumer complaints led to a Code Participant identifying that an Authorised

Representative did not send policy renewal notices to some consumers at least 14 days prior to the renewal date.

3. A Code Participant’s investigation of consumer complaints found that an employee had created two different types of policies for consumers without their permission.

4. An employee mistakenly copied and transferred policy exclusions from the wrong insurance product to an insurance product that it was selling online. 5. A team responsible for verifying the content of online material did not detect

the error because it was unaware of the proposal to change the content of the product’s Product Disclosure Statement (PDS).

As a result of the error, consumers who bought the insurance product online had viewed a PDS that contained the wrong policy exclusions.

6. During monitoring of sales activities a Code Participant found that some Authorised Representatives had recommended consumers replace their existing cover without providing a suitable explanation for their

recommendations.

7. Consumer complaints led to a Code Participant finding that several

Authorised Representatives had issued policies that fell outside the scope of its underwriting guidelines.

(15)

We have described below the types of actions that individual Code Participants used to correct breaches of the standards that apply to buying insurance during 2013–14.

Tips for industry: handling significant breaches

We handled five significant breaches of section 2 during the year. One significant breach involved a Code Participant who did not report the matter to us because it had:

 Characterised the underlying issue as an IT fault only.

 Wrongly concluded that it had complied with its obligation to conduct its sales processes in a fair, honest and transparent manner (section 2.1.4).

The Code Participant applied the wrong premium discounts due to an error in its policy administration system. As a result, 6,651 consumers were overcharged when renewing their motor vehicle policies. It returned $644,892 in overpaid premiums to affected consumers including interest in remediation of the breach.

In addition, the Code Participant repaired the technical fault in its policy administration system, audited the system to ensure it continued to operate effectively and introduced monthly monitoring to prevent a recurrence of the issue.

Examples of actions taken to address non-compliance with standards applicable to buying insurance

1. Addressing concerns directly with consumers. This included issuing the correct policy documentation to consumers or refunding premiums and paying interest on the refunded amount where necessary.

2. Reviewing other transactions carried out by employees or Authorised Representatives to determine whether additional consumers were affected by non-compliant conduct.

3. Providing coaching, training and/or counselling to individual employees and Authorised Representatives.

4. Giving feedback to a team of individuals to further embed the correct procedure and remind them of Code compliance obligations.

5. Implementing quarterly reviews of insurance applications.

6. Withholding commission from Authorised Representatives and/or issuing a written warning to them.

7. Dismissing employees or terminating an Authorised Representative’s contract.

(16)

Our top three tips for industry from our observations in dealing with significant breaches are:

3. When considering whether an issue is a significant breach, ensure that you have fully

documented your

deliberations. We will ask for this when we are

investigating a potential significant breach of the Code.

2. Be cautious when considering whether an issue should be

characterised solely as an IT failure or human error. Consider the wider

implications and impact of the issue on consumers, having regard to

obligations to conduct sales processes and services in an efficient, fair, honest and transparent manner.

1. When restructuring incident reporting

mechanisms and/or risk and compliance teams, ensure that you also maintain capacity to undertake timely

investigation and reporting against Code obligations – both internally and

(17)

8 Claims, declined claims and withdrawn claims

Industry overview

The overall 2013–14 data is presented in Table 6.

Table 6: Personal and commercial general insurance classes – overview of number of claims, declined claims and withdrawn claims in 2013–14 and variation against 2012–13 data

TYPE OF GENERAL INSURANCE

Number of Claims Number Declined Claims Number of Withdrawn Claims PERSONAL CLASSES 3,410,691 Up 5% 105,945 Up 12% 127,865 Down 26% COMMERCIAL CLASSES 507,578 Down 6% 4,353 Down 10% 4,044 Up 114% ALL CLASSES 3,918,269 Up 4% 110,298 Up 11% 131,909 Down 24% When compared with 2012–13 the data shows that:

 In 2013–14 the number of claims lodged by consumers increased slightly: overall claims increased 4% while the number of personal insurance claims increased 5%.  Code Participants declined more general insurance claims in 2013–14. This was

influenced by a 12% increase in the number of declined personal insurance claims. At the same time, the ratio of declined personal insurance claims to personal

insurance claims remained stable: 3.1% in 2013–14 compared with 2.9% in 2012–13. This means that Code Participants declined about 3 personal insurance claims for every 100 personal insurance claims.

 In 2013–14 the number of withdrawn claims reported by industry within all classes of insurance fell 24%, due to a 26% fall in the number of withdrawn claims within personal classes of insurance.

Withdrawn claims

We had two objectives when we began collecting data and information about withdrawn claims in 2011–12:

1. That more Code Participants would report data about the number of withdrawn claims and the reasons claims were withdrawn. In this reporting period, 71 Code Participants provided data and information about withdrawn claims compared with 61 Code Participants for the previous period.

While the number of Code Participants with a capacity to report this type of data and information continues to grow, more needs to be done. Some Code Participants remain unable to report any information about withdrawn claims due to incompatible or outdated data systems.

2. Encourage industry to develop a more efficient and accurate capacity to report this data together with the reasons claims are withdrawn, across all classes of personal insurance. While the number of Code Participants reporting this type of information

(18)

continues to grow, their capacity to report remains inconsistent and does not extend to all personal classes of insurance that they deal in.

Common reasons for withdrawal of claims

Industry identified some reasons for the withdrawal of that were common to one or more personal insurance classes such as:

 there was no cover in place

 the claim was investigated and subsequently withdrawn  consumers wanted to avoid a formal claim denial  consumers had lodged claims with the wrong insurer

 the value of the claim was low or less than the applicable excess  consumers decided they no longer wanted to pursue their claims  the event or incident did not cause any damage to the insured property  consumers decided to repair the damage at their own cost

 the claim was not covered due to a policy exclusion or because the policy did not provide cover for the particular type of damage or loss, and

 consumers obtained a report which showed that the damage or loss was due to a cause that was not covered.

Industry also noted that they have recorded some claims as withdrawn in circumstances where:

 consumers did not respond to requests for further documentation/information

 claims were opened in error due to duplication or lodgement against the wrong policy, and

 there was no further contact from claimants.

Industry trends

Table 7 outlines the number of claims, declined claims and withdrawn claims by class of personal insurance and includes the extent to which the data varied (by %) compared with 2012–13.

The same data is presented in Chart 8 as:

 Claims by class as a proportion (%) of all personal insurance claims.

 Declined claims by class as a proportion (%) of all declined personal insurance claims.  Withdrawn claims by class as a proportion (%) of all withdrawn personal insurance

(19)

Table 7: Personal classes of general insurance – number of lodged, declined and withdrawn claims in 2013–14 and variation against 2012–13 data

Motor

The data shows that during 2013–14 industry:

 Received 1,875,728 Motor claims (up 9%) representing the largest category of personal insurance claims.

 Declined 6,282 claims. This was down 16% and accounted for 6% of declined personal insurance claims.

 Reported that consumers withdrew 63,578 claims (down 20%) representing half of all withdrawn personal insurance claims.

Industry reported consumers withdrew Motor claims for various reasons including that:  consumers did not subsequently receive a third party demand for payment of repairs  stolen motor vehicles were later recovered by police with little or no damage

 consumers did not want their claim to affect their no claim bonus (NCB)  consumers did not provide a repair quote

 third parties/insurers accepted liability

 each driver covered their own repair costs, and

 the motor vehicle was not insured for the claimed damage (for example, covered only for third party property damage).

Number of Claims Number of Declined Claims

Number of Withdrawn Claims

PERSONAL CLASSES OF GENERAL INSURANCE

Accident & Sickness 48,894 Down 16% 1,553 Down 16% 1,064 Up 859% Consumer Credit 26,237 Down 9% 3,791 Up 19% 1,126 Up 21% Home 714,768 Down 8% 36,213 Down 14% 52,423 Down 33% Motor 1,875,728 Up 9% 6,282 Down 16% 63,578 Down 20% Personal & Domestic

Property 441,116 Up 23% 32,930 Up 72% 5,235 Down 31% Residential Strata 55,147 Down 20% 905 Up 19% 159 Down 42% Travel 248,801 Up 4% 24,271 Up 21% 4,280 Down 6% TOTAL 3,410,691 Up 5% 105,945 Up 12% 127,865 Down 26%

(20)

Chart 8: Personal classes of general insurance – % of lodged claims by class, % of declined claims by class and % of withdrawn claims by class in 2013–14

Home

All Home claims, declined claims and withdrawn claims data was down against 2012–13 data. Industry identified improved weather conditions during 2013–14 as a major influence on claim numbers. Home accounted for:

 21% – 714,768 – of personal insurance claims

 34% – 36,213 – of declined personal insurance claims. This is the largest category of declined insurance claims, and

 41% – 52,423 – of withdrawn personal insurance claims. Industry reported that consumers withdrew Home claims because:  an insured event or incident did not result in any damage  consumers did not want their claim to affect their NCB  stolen property was recovered with little or no damage  consumers did not provide proof of loss, or

55% 21% 13% 7% 2% 1% _1% 6% 34% 31% 23% 1% 1% 4% 50% 41% 4% _3% 0% 1% 1% 0% 10% 20% 30% 40% 50% 60%

Motor Home Personal & Domestic Property Travel Residential Strata Accident & Sickness Consumer Credit Personal classes of general insurance

% Lodged claims by class % Declined claims by class % Withdrawn claims by class

(21)

 consumers repaired the damage at their own cost.

Personal & Domestic Property

In relation to Personal & Domestic Property data:

 Claim numbers increased 23% to 441,116. This accounted for 13% of all personal insurance claims lodged during 2013–14.

 The number of declined claims increased 72% to 32,930. This accounted for 31% of all declined personal insurance claims.

Industry identified the following factors that may have contributed to variation in the data in 2013–14:

 The increase in claims and declined claims was consistent with growth in sales of particular products, such as those covering laptops, mobile phones or pets.  Code Participants sharpened their focus on applying the policy wording to the

assessment of claims which contributed to an increase in declined claims.

 Consumers lodged some claims that were not covered by their policies contributing to the incidence of declined claims.

 There has been a growth in consumers electing a higher policy excess. As a result, more claims were declined on the basis that the value of the claim was less than the applicable excess.

 Changes in the features of some products led to a reduction in cover. As a result, some claims were no longer covered and were declined.

Industry reported 5,235 withdrawn claims, down 31%. It also reported that consumers withdrew claims for a range of reasons including that property reported as lost was found subsequently.

Travel

The data shows that:

 Consumers lodged 248,801 Travel insurance claims (up 4%), representing 7% of all personal insurance claims.

 Industry declined 24,271 claims in 2013–14, up 21%. This accounted for 23% of all declined personal insurance claims.

 Consumers withdrew 4,280 claims (down 6%).

Industry reported that the following factors may have contributed to the increase in declined claims:

 Consumers lodged some claims that were not covered by their policies.

 Code Participants sharpened their focus on applying the policy wording to the assessment of claims.

(22)

Residential Strata

While the number of Residential Strata claims fell to 55,147 (down 20%) declined claims increased 19% to 905. Code Participants were unable to identify any factors that may have contributed to the increase in declined claims for this class of insurance.

Accident & Sickness

The number of Accident & Sickness claims and declined claims fell 16% in 2013–14. Code Participants reported that the decrease in numbers may have been due to improved underwriting procedures and acceptance guidelines for both new and renewed policies, reducing their exposure to poorly performing policies.

The data shows that withdrawn claims increased to 1,064 which Code Participants have attributed to better follow-up on outstanding claims. Code Participants also reported that claims were withdrawn because:

 Medicare sometimes covered the claimed costs

 no further treatment was required by some consumers, and

 in some disability claims consumers had not exhausted the excess period that applied under the policy and as a result, they were not entitled to payments.

Consumer Credit Insurance

While Consumer Credit Insurance claims fell 9% to 26,237, the number of declined claims increased 19% to 3,791. Code Participants reported that the increase in declined claims was not significant given the low data volume and identified a number of factors influencing declined claims rates including:

 the claim falling outside the terms of the policy

 claims made when there was no insurance cover in place, and

 the event giving rise to the claim occurred before inception of the policy.

Withdrawn claims in this class increased by 21% although from a very low base. Code Participants reported that consumers withdrew claims for various reasons including that:  consumers returned to employment, and

 there was no loan balance to pay out under the policy.

These factors suggest that consumers do not have a clear understanding of how these products operate.

Industry compliance data on claims handling

Section 3 of the 2012 Code contains extensive standards that underpin the way in which Code Participants, their employees and Service Providers provide claims handling services to consumers. The standards include obligations to:

 Decide whether to accept a claim and inform a consumer of the decision within 10 business days of receiving their claim (section 3.1 and section 3.2.5).

(23)

 Update a consumer on the progress of their claim at least every 20 business days (section 3.2.3).

 Notify a consumer of a decision to decline a claim (this must be done in writing), informing them of their right to ask for the information that a Code Participant relied on in assessing their claim and their right to ask for a review of any decision to refuse to release that information (section 3.5.5(b)).

 Handle all claims and provide all claims services in an honest, efficient, fair, transparent and timely manner (sections 3.5.1 and 3.7.1).

During 2013–14 industry reported that it had identified and addressed 3,835 breaches of section 3. This represented 68% of all industry-identified non-compliant activity.

We have discussed some of these breaches and their causes, and provided some examples of industry’s remedial actions below.

Access to information used to deny a claim

Industry identified and reported 1,849 breaches of its obligation to inform a consumer of their right to:

(a) access information that a Code Participant relied on in assessing their claim, and (b) ask for a review of any decision to refuse to release that information.

This information must be provided by Code Participants when notifying consumers of a decision to decline their claim. This non-compliant conduct accounted for 48% of all claims handling breaches and 33% of all breaches identified and reported by industry across all classes of insurance.

Code Participants addressed the non-compliant activity by:  Informing all affected consumers of their rights in writing.

 Updating procedures manuals, and amending claim denial templates and complaints brochures to ensure compliance with obligations.

 Informing claims staff of the changes to procedures and template documents.

Updating consumers on claim progress

Industry identified and reported 645 breaches of the obligation to update a consumer on the progress of their claim at least every 20 business days (section 3.2.3).

Code Participants identified several causes underlying the non-compliant activity including:  The introduction of new claims systems that affected the ability of claims staff to update

consumers at least every 20 business days.

 Unexpected seasonal events that affected staff resourcing. As a result claims staff were unable to update consumers at least every 20 business days.

(24)

Some of the types of actions implemented by Code Participants to address breaches of the standard included:

 Refresher training for claims staff to improve their awareness of Code requirements and procedures.

 Providing progress updates to affected consumers.

 Providing additional support for claims staff and improving training.

Making a claim decision and notifying a consumer

Industry identified and reported a total of 731 breaches of its obligation to decide whether to accept or deny a claim and inform a consumer of the decision within 10 business (532 breaches of section 3.1 and 199 breaches of section 3.2.5 respectively).

Here are two examples of how this type of non-compliance occurred and what each Code Participant did to rectify it.

Some staff did not follow procedure and as a result failed to accept or deny some claims within 10 business days. The Code

Participant’s Team Leaders identified the issue by monitoring claims handling timeframes on a monthly basis.

The Code Participant contacted all affected consumers and informed them of its claim decision. In addition, Team Leaders provided feedback and coaching to claims staff.

A Code Participant’s Service Provider identified a system error when claim volumes appeared to fall significantly. As a result, in some instances the Service Provider was unable to make a decision whether to accept or deny the claim within 10 business days.

The Service Provider addressed the issue by contacting all

affected consumers about the delays, prioritising the processing of affected claims and repairing the system error.

(25)

Honest, efficient, fair, transparent and timeliness

Industry reported non-compliance with its obligation to handle claims and conduct claims services in an honest, efficient, fair, transparent and timely manner in 110 instances (sections 3.5.1 and 3.7.1).

Here are two examples of how the non-compliance occurred and how it was addressed.

A Code Participant identified a number of instances where prior to closing claim files employees did not return motor vehicle claim excesses to a number of consumers. They were entitled to a refund of their excesses because the Code Participant confirmed that a third party driver was liable for the incident. This issue was identified during an internal audit review carried out by the Code Participant’s audit team.

The Code Participant addressed this matter by refunding the excesses to affected consumers including interest. It introduced a monthly management report to capture finalised claim files and identify and refund claim excesses, where required. It also introduced a claim finalisation checklist for all claims staff to reinforce the aspects that should be checked and verified before closing files.

A Code Participant reported that during a brief period some consumers experienced delays in receiving claim payments. The Code Participant determined that due to an administrative oversight a claims team did not receive the usual daily reports which included customer account information to enable claim payments to occur.

The Code Participant became aware of the issue when the claims team followed up the absence of the reports.

(26)

Tips for industry

We handled 12 significant breaches of various claims handling standards during 2013–14 comprising:

 Six significant breaches which affected 12,192 consumers and resulted in payments of $122,767 to consumers including interest.

 Six significant breaches encompassing 13,790 instances of non-compliance.

We also dealt with 188 breaches affecting 1,980 consumers where industry, in notifying consumers of a decision to decline their claim, did not comply with the obligation to inform consumers of their right to ask for:

 the information that a Code Participant relied on in assessing their claim (section 3.5.5(b)(i)), and

 their right to ask for a review of any decision to refuse to release that information, (section 3.5.5(b)(ii)).

We have collated our top tips for industry on claims handling, based on our observations of industry-identified data and our handling of significant breaches here.

1. Regularly monitor the performance of claims staff and Service Providers against claims handling obligations through, for example:

 The review of open and closed claims files to assess the quality of decision-making, adherence to claims timelines and transparency during the claims process.

 Annual reviews of Service Providers.

 Monitoring and analysis of complaints and disputes about claims handling and decision-making, including the outcomes of disputes lodged with FOS.

This will enable Code Participants to identify poor practices as early as possible and timely rectification of issues.

2. Ensure that claims handling procedures clearly identify which business areas are responsible for each part of a claims process.

3. Support a culture where employees and Service Providers report potential compliance issues to the business’s risk and compliance area immediately. Ensure that they understand that reporting incidents is actively encouraged and that they are aware of the process for escalation.

4. Ensure that there is active oversight of compliance at all levels of management up to and including board level.

5. Identify all causes of an issue and develop and implement an effective and timely action plan to address the cause and prevent reoccurrence.

(27)

9 Financial hardship

Industry compliance data

Of the 3,835 Code breaches self-identified by industry in 2013-14, only five of these breaches involved the third party financial hardship provisions of the 2012 Code, which ensure that industry:

 Acts fairly and in a considerate manner when dealing with third parties in accordance with the ACCC & ASIC Debt Collection Guideline: for Collectors and Creditors (the Guideline).9_{The Guideline helps collectors and creditors to understand how the} Commonwealth consumer protection laws apply to their activities. (Section 3.11.)  Genuinely considers the financial position of third parties in financial hardship and debt

repayment options. (Section 3.12.)

 Makes available internal complaints processes to third parties if unable to agree on debt repayment and provide information about Financial Counselling Australia10 for referral to a non-for-profit, free financial counselling service. (Section 3.13.)

Here are four instances of non-compliance with the financial hardship standards.

9_{For further information go to: Debt collection guideline for collectors & creditors | ACCC and RG 96 Debt collection}

guideline: For collectors and creditors | ASIC - Australian Securities and Investments Commission.

10_{For further information go to: http://www.financialcounsellingaustralia.org.au/Home.}

Examples of non-compliance with financial hardship standards

1. An employee did not provide the third party with information about the debt (section 3.11). The Code Participant took steps to comply with the specific debt collection guideline and provided remedial training to the employee.

2. An employee did not consider a debt repayment option which extended the period of repayment and postponed payments for an agreed period (section 3.12(c)), when dealing with an

application for third party financial hardship assistance. The Code Participant addressed the issue by taking the option into account and providing remedial training to the employee. 3. An employee did not provide information about relevant complaints handling procedures to a

third party in financial hardship, when they were unable to reach an agreement about debt repayment (section 3.13(a)). The Code Participant responded by providing the required information and reviewing template documents to ensure they contained the relevant information.

4. A Code Participant did not provide information to a third party in financial hardship about its complaints process and referral to Financial Counselling Australia (sections 3.13(a) and (b)). It addressed the issue by improving its procedures and re-training employees in its recoveries area.

(28)

Tips for industry

The 2014 Code has highlighted the importance industry places on dealing with financial hardship in a fair, genuine and practical way. All standards that apply to financial hardship have been enhanced and sit within section 8 of the 2014 Code. We note in particular that:  The standards of section 8 are not limited to third parties and from 1 July 2015 they

extend to insureds and third party beneficiaries (excluding hardship in respect of payment of premiums under a policy issued by a Code Participant).

 A Code Participant and its Collection Agents must suspend recovery action when they have received an application for financial hardship assistance (section 8.7).

 A person in financial hardship may ask a Code Participant to consider a release, discharge or waiver of a debt or obligation (section 8.8(c)).

While industry reported an extremely low incidence of non-compliance with financial hardship standards in 2013–14, we recommend that industry monitors this area carefully, particularly after 1 July 2015 when the 2014 Code becomes operational.

(29)

10 Responding to catastrophes and disasters

Industry compliance data

Industry reported 33 breaches of its obligation to notify a consumer of:

 their right to request a review of the settlement of their claim up to six months after finalisation, even if the consumer has signed a release, if they believed that the assessment of their claim was inaccurate or incomplete (section 4.3(a)), and

 its complaints procedures (section 4.3(b))

in response to a property claim that arose from a catastrophe or disaster and which was finalised within one month of the event.

An example of non-compliance with these obligations is outlined below.

Tips for industry

We handled a significant breach of section 4.3 during 2013–14 which affected 392 consumers. It was caused by amendments to template documents that wrongly altered settlement review timeframes from six months to one month and removed information about internal complaints processes. This is a common occurrence. We have highlighted our top three tips for industry when reviewing and updating templates.

1. Have stringent review and sign off practices in place for the creation and updating of templates.

2. Monitor the use of updated template documents to ensure that unauthorised or unexpected changes have not been made.

3. Monitor the use of template documents to ensure that employees and Service Providers are using them when required.

4. Remove all old and obsolete templates.

Employees of a Code Participant wrote to consumers using a template document that did not include information about consumers’ right to review the terms of settlement. This was addressed by updating the template document, notifying each consumer of their right to a review and providing additional training and support for employees.

(30)

11 Internal disputes

Complaints and disputes

Code Participants are required to have an internal process for dealing with complaints and disputes received from their customers and from third parties in defined circumstances. This internal process is described as an internal dispute resolution (IDR) process and usually consists of an internal complaints phase (stage one) and an internal disputes phase (stage two). These standards are described by section 6 of the 2012 Code.

Code Participants also have an obligation to inform a consumer about their right to refer an unresolved dispute to FOS’s external dispute resolution process.11

Industry overview

The overall 2013–14 internal disputes data is presented in Table 9. The data shows that consumers lodged 15% fewer internal disputes with Code Participants during 2013–14. This was mainly due to a 16% fall in internal disputes about personal insurance products and services.

Table 9: Overview of internal disputes data 2013–14

A fall of 13% in the number of internal disputes finalised by Code Participants is consistent with the 15% fall in internal disputes lodged by consumers. The proportion of internal disputes finalised in favour of consumers remains relatively unchanged – about 30% of internal disputes are finalised by Code Participants in favour of consumers.

11_{Acceptance of a dispute by FOS is dependent on its Terms of Reference.}

Personal Classes of General Insurance

Commercial Classes of General Insurance

All Classes Number of internal disputes 25,486

Down 16%

1,591 No change

27,077 Down 15% Number of finalised disputes 25,957

Down 14%

1,609 Down 9%

27,566 Down 13% Number disputes finalised in

favour of Code Participants

18,704 (72%) 1,201 (75%) Number of disputes finalised

in favour of Consumers

7,253 (28%) 408 (25%) The 2012 Code defines “complaint” and “dispute” as follows:

"Complaint" means an expression of dissatisfaction made to us related to our products or services or to our complaints handling process where a response or resolution is explicitly or implicitly expected.

(31)

Industry trends

We have provided data about internal personal insurance disputes by class in Table 10 consisting of the:

 Overall number of internal disputes that consumers lodged with Code Participants across all types of internal disputes – Internal Disputes.

 Number of internal disputes that consumers lodged about claims across all types of internal claims disputes – Internal Claims Dispute. This data includes internal disputes about a Code Participant’s decision to decline a consumer’s claim.

 Number of internal disputes that consumers lodged solely about declined claims – Internal Disputes about Declined Claims. Code Participants reported this data to us as a sub-category of internal disputes about claims.12

The remaining column – Declined Claims – outlines the number of declined claims in each personal insurance class. We also discuss data about declined claims in Part 8 of this report. Table 10: Personal Insurance: internal disputes and declined claims 2013–14

DISPUTES LODGED

1 2 3 4

Declined Claims Internal Disputes Internal Claims Disputes Internal Disputes about Declined Claims (as a % of Claims Disputes) PERSONAL

Accident & Sickness 1,553 Down 16% 276 Up 5% 250 Up 1% 228 (91%) Consumer Credit 3,791 Up 19% 426 Up 25% 368 Up 28% 202 (55%) Home 36,213 Down 14% 8,942 Down 26% 6,474 Down 28% 4,171 (64%) Motor 6,282 Down 16% 12,189 Down 15% 10,098 Down 15% 3,222 (32%) Personal & Domestic Property 32,930

Up 72% 957 Up 23% 786 Up 15% 624 (79%) Residential Strata 905 Up 19% 297 Down 28% 281 Down 27% 194 (69%) Travel 24,271 Up 21% 2,399 Up 15% 2,334 Up 40% 1,849 (79%) PERSONAL TOTAL 105,945 Up 12% 25,486 Down 16% 20,591 Down 14% 10,490 (51% )

Our analysis of internal disputes data shows that 81% of disputes lodged by consumers internally with Code Participants were about claims. Moreover, 51% of internal claims

12_{This is the first year that we have provided data about declined claims disputes. As a result, we have not provided any}

(32)

disputes were about a Code Participant’s decision to decline a claim. This is consistent with FOS’s experience with external disputes about general insurance products and services.13 The data shows that the number of internal disputes fell 16% to 25,486 and the number of internal disputes about claims also fell 14% to 20,591.

FOS reported that during the same period it accepted 6,193 domestic general insurance disputes, down 12% on 2012–13 data.14

Most internal disputes were about the following three classes of personal insurance: 3. Motor — 12,189 internal disputes, down 15%.

4. Home — 8,942internal disputes, down 26%. 5. Travel — 2,399 internal disputes, up 15%.

Code Participants reported that falls in internal dispute numbers could be attributed to:  improved claims management

 reduction in claims processing times and following up on third party evidence  greater emphasis on resolving complaints at the first point of contact, and

 more effective and efficient complaints handling in stage one of the internal complaints process, reducing the need for escalation of disputes to stage two.

Consumer Credit

Consumers lodged:

 25% more internal disputes overall about Consumer Credit insurance products and services.

 28% more internal disputes about Consumer Credit insurance claims in 2013–14. The data shows that most internal disputes were about a Code Participant’s decision to decline a claim – declined claims increased by 19% to 3,791.

Code Participants did not report any factors that may have contributed to these increases and noted that low values may lead to a large proportional variation.

Home and Motor

All internal disputes data was down for these classes of insurance compared to 2012–13. In relation to Home, 4,171 internal disputes and for Motor, 3,222 internal disputes, were about a decision to decline a claim (representing 64% and 32% of internal claims disputes respectively).

Some Code Participants have reported that improved efficiency and more effective complaints handling, particularly in stage one of the internal complaints process, contributed to a fall in

13_{See page 60, Annual Review 2013–2014, Financial Ombudsman Service, www.fos.org.au.} 14_{See footnote 13 above.}

(33)

internal disputes in both classes of insurance. Other Code Participants attributed the fall in internal disputes to:

 Staff training and development which improved their ability to effectively explain the reasons a claim item or incident was not covered by a policy.

 Implementation of processes which increased the number of disputes being resolved in stage one of the internal complaints process.

Personal & Domestic Property

In relation to Personal & Domestic Property insurance:

 Industry reported that consumers lodged 957 internal disputes about products and services, up 23%. This included 786 internal disputes about claims, up 15%.

 Of these 786 internal claims disputes, 624 disputes were about declined claims. At the same time, Code Participants declined 32,930 claims, up 72%.

Several Code Participants reported that the gap between the number of declined claims and the number of internal disputes may be due to the following factors:

 Many internal disputes were resolved during stage one of the internal complaints process.

 Many declined claims were of low value and so consumers were less inclined to dispute them.

 For some products such as pet insurance, consumers claimed several times per year and so they were less inclined to dispute a decision to decline a claim.

 Some products were changed during 2013–14 which resulted in lower internal disputes and improved customer satisfaction. For example, some exclusions and policy limits were removed.

Travel

We note that in relation to Travel:

 The number of internal disputes about products and services increased 15% to 2,399 and included 2,334 internal disputes about claims, up 40%.

 Of these 2,334 internal claims disputes, 1,849 disputes were about declined claims, against a 21% increase in declined claims to 24,271.

Some Code Participants reported that the increase in internal Travel disputes was consistent with a growth in sales, claims and declined claims. Other Code Participants attributed this to an increase in the number of issues escalated by staff.

(34)

Industry compliance data

Industry reported that it identified 1,123 instances of non-compliance with various aspects of section 6.

This accounted for 20% of all industry-identified breaches. This included 902 breaches of industry’s obligation to respond to an internal dispute within 15 business days, provided no further information and investigation is needed (section 6.6(c)).

Industry reported that this non-compliance was primarily associated with a failure to follow procedures.

To address the non-compliance Code Participants:  increased staff numbers

 provided coaching to staff, and

 contacted affected consumers and agreed on alternative timeframes for complaint responses.

These instances highlight the importance of Code Participants providing adequate staffing resources for areas of the business responsible for internally reviewing

consumers’ complaints and disputes. This will ensure that employees involved in internal complaints processes have a capacity to:

 correctly apply internal complaints processes

 adhere to timeframes for completion of each stage of the internal complaints process, and

(35)

(36)

A: Current Code Participants

General Insurers

1. AAI Limited

2. ACE Insurance Limited

3. AIG Australia Ltd

4. AIOI Nissay Dowa Insurance Company Australia Pty Ltd

5. Allianz Australia Insurance Limited

6. Ansvar Insurance limited

7. Assetinsure Pty Ltd

8. Auto & General Insurance Company Limited

9. AVEA Insurance Limited

10. Calliden Insurance Limited

11. Catholic Church Insurance Limited

12. CGU Insurance Limited (CGU)

13. Chubb Insurance Company of Australia Limited

14. Commonwealth Insurance Limited

15. Credicorp Insurance Pty Ltd

16. Defence Service Homes Insurance Scheme

17. Factory Mutual Insurance Company

18. Genworth Financial Mortgage Insurance Pty Ltd

19. Great Lakes Re-insurance (UK) PLC

20. Guild Insurance Limited

21. Hallmark General Insurance Company Limited

22. HBF Insurance Pty Ltd (HBF)

23. Insurance Australia Limited

24. Insurance Manufacturers of Australia Pty Limited

25. LawCover Insurance Pty Limited

26. Lloyd’s Australia Limited

27. Medical Insurance Australia Pty Ltd

28. Mitsui Sumitomo Insurance Co Ltd

29. MTA Insurance Limited

30. Mutual Community General Insurance Proprietary

Limited

31. NTI Limited

32. OnePath General Insurance Pty Limited

33. Progressive Direct Insurance Pty Ltd

34. QBE Insurance (Australia) Limited

35. QBE Lenders’ Mortgage Insurance Limited

36. RAA Insurance Limited

37. RAC Insurance Pty Limited

38. RACQ Insurance Limited

39. RACT Insurance Pty Ltd

40. Sompo Japan Nipponkoa Insurance Inc

41. Southern Cross Benefits Limited

42. St Andrew’s Insurance (Australia) Pty Limited

43. Sunderland Marine Mutual Insurance Company Limited

44. Swann Insurance (Aust) Pty Ltd

45. Territory Insurance Office

46. The Hollard Insurance Company Pty Ltd

47. The Tokio Marine & Nichido Fire Insurance Co Ltd

48. Virginia Surety Company Inc

49. WFI Insurance Limited

50. Westpac General Insurance Limited

51. XL Insurance Company Ltd

52. Youi Pty Ltd

2012 General Insurance Code of Practice Aggregated Industry Data Report Overview of the Year