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CGC cracks down on financial hardship obligations

An investigation of insurer websites has found many are not complying with rules for communicating financial hardship options to customers.

The General Insurance Code Governance Committee (CGC) examined 49 websites to see if insurers are complying with the “spirit and intent” of the General Insurance Code of Practice.

It exposed potential breaches of the code, and said in general many websites made the process difficult or off-putting. 

“One website took six clicks and over 20 minutes to find the information. The path was complex and not where a consumer would look,” the inquiry said. 

“Adhering to the code is not just a matter of ticking boxes and meeting minimum standards.”

Insurers should “comply with the spirit and intention” by prioritising the needs of consumers. Processes for dealing with financial hardship assistance requests should be “responsive, flexible and fair”.

The Committee made nine recommendations, and says it will be writing to two insurers that provided inaccurate information on their websites.

"Lack of attention to this can create the impression that a subscriber sees the requirement as a pure compliance exercise,” it said. "We consider information to be off-putting to a consumer if it is not set in the right tone or could potentially deter or discourage someone genuinely seeking support.”

While insurers may be concerned about receiving numerous requests for financial hardship that may not be genuine, the Committee says that “risk is low”.

“Most people are reluctant to apply for financial hardship support because of the stigma ... or perceptions that there is little value in asking for help.”

Eight websites were found to have no information about Financial Hardship support, while six had not provided information on the type of support options available. One did not have its own separate website.

“There is some work to do in terms of how the information is published on subscribers’ websites. The information should be accessible to all, easy to find and not buried amongst other information,” Committee Independent Chair Veronique Ingram said.

“It should be clear, easy to understand and conveyed in a compassionate tone. It should provide information on the support options available and multiple methods for how a consumer can contact the subscriber for assistance.

“We want firms to … take immediate action where necessary to ensure that they are well placed to support consumers experiencing financial hardship or the threat of it.”

Ms Ingram says insurance is an expense that many would likely forgo when cutting back their expenses and supporting customers in financial hardship effectively “is therefore good for business, and more importantly, it is the right thing to do”.  

On 27 websites, the information was not easy to find. Thirteen placed a link to the Financial Hardship support information at the footer of the website where the fine print is typically located amongst various other links. 

"A consumer would not typically look for such information in the footer of a website. Having to scroll to the bottom of the page is not considered accessible or easy to find,” the Committee said.

Eighteen websites did not have the link to the information on Financial Hardship support appropriately named, with the information on the ‘About Us’ page, ‘Forms and Publications’ or ‘Key Policies’. 

“Most consumers would not be able to easily locate such information. The reference to 'Key Policies' is also potentially confusing for consumers in the context of an insurance policy.

“Information about Financial Hardship support should be visible and easy to find, prominently located and links should be logically named. Vital information about how to get Financial Hardship support should not be lost amongst other information.”

Five websites provided “too much information and were not written in plain English,” while six were deemed unhelpful as they provided very little information and one "read like an internal policy” that was difficult for a consumer to understand.

A quarter provided information that was off-putting.

“It made the process seem daunting,” the Committee said.

Some websites mentioned evidence of unemployment may be requested but the Committee said this fact must be “conveyed on websites in the appropriate and sensitive manner, noting that the audience is likely to be someone already experiencing stress and anxiety.” 

The inquiry found just seven websites provided information that was easy to find, easy to understand, helpful and not off-putting. 

Two insurers were commended for providing information in different languages on their website, and another for placing the link prominently in the middle of the web page. 

See the inquiry report here.