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April 2013 – the new regulation regime and specific policies

Apr 04, 2013
by Andrew@Reliabilityoxford.co.uk
0 Comment
Paragraphs 11 and 12 of the PRA guidance paper insuranceappr1304 refer to market failure at the level of a given type of insurance policy e.g. third party motor insurance. The concern is that the beneficiaries of a policy would be denied their rights in the event that an insurer gets into difficulty. Of course, there are mechanisms for the market to pick up the tab for some kinds of insurance policy when an insurer goes out of business.

The implication might be that PRA will take a market level view of threats to individual policy types e.g. Employer’s Liability, the more so the more difficult it would be to manage economic risks were those insurances to be withdrawn for whatever reason. EL is of course compulsory, so employment would be impossible without it, Prof Indemnity is highly advisable, its absence would not be in the interests of commerce or the beneficiaries of third party policies.

Market-wide action on general threats to policy lines would seem to be the obvious response – otherwise the PRA is asking insurers to subsidise policy lines in times of difficulty. This may not always be possible.

While concerted action on pricing would be politically difficult, PRA could act as a mechanism for market hardening by for example ensuring that reserves against a given policy line are adequate. The guidance seems to take a dim view of revenue expansion as the mechanism for getting out of trouble – this would simply increase the number of unmet rights should the strategy fail.

The question is then how would a competitive market respond to the PRA setting out to protect a given insurance product.

 

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