Optima - Actuarial and Insurance Consultants€¦ · beware, issues of operational pragmatism, the actual need for fine print in insurance contracts, and the fact that the most common

Optima | General Insurance Insights | 2018 1

Optima General Insurance InsightsRegulatory turbulence 2018


Regulatory turbulenceA look at the regulatory landscape after the storm dies down

The regulatory landscape for insurers is already very complex, and 2018 has seen a flurry of activity that may well increase the complexity and the demands. This article touches on the things that insurers have been dealing with, calls out the disruption that is being caused to normal business and offers a few thoughts as to how insurers might handle the situation.

The Royal Commission into Misconduct in the Banking,

Superannuation and Financial Services Industry is just the most

recent (and high profile) of a raft of reviews into or affecting the

General Insurance industry. Starting with the Financial Systems

Inquiry in 2014 we have counted no less than 17 national inquiries

or reviews into or affecting general insurers.

“ Walk on through the wind Walk on through the rain”You’ll Never Walk Alone Gerry and the Pacemakers

FEATURE: REGULATORY TURBULENCE

Image credit J.M.W Turner (1775–1851)

Snow Storm – Steam-Boat off a Harbour’s Mouth, exhibited 1841

Oil on canvas, The TATE


Timeline of inquiries and legislation affecting General Insurance

2014

• Financial System Inquiry (December 2014)

Insurance Council of Australia

• Revised General Insurance Code of Practice (2014)

2015

Productivity Commission

• Natural Disaster Funding Inquiry (May 2015)


• Too Long; Didn’t Read – Enhancing General Insurance Disclosure (October 2015)

2016

Treasury

• Northern Australia Insurance Premium Taskforce (March 2016)

ASIC

• A market that is failing consumers: the sale of add-on insurance through car dealers (September 2016)

2017

Senate Economics References Committee Report

• General insurers sapping consumers of the will to compare (August 2017 )

Treasury Laws Amendment

• Design and Distribution Obligations (exposure draft December 2017 )

ACCC

• Northern Australia Insurance Inquiry (ongoing)

ASIC

• The sale of add-on insurance and warranties through car yard intermediaries (August 2017 )

2018

Royal Commission into Financial Services (ongoing)

Australian Law Reform Commission

• Inquiry into Class Action Proceedings and Third-Party Litigation Funders (ongoing)


• Design and Distribution Obligations (second exposure draft July 2018)


• Extending Unfair Contract Terms to Insurance Contracts (June 2018)


• General Insurance Code of Practice Review (June 2018)

APRA

• Role of the Appointed Actuary (June 2018)

Australian Financial Complaints Authority (in effect from 1 November 2018)

Notifiable Data Breaches Regime (February 2018)

APRA

• Draft Prudential Standard CPS 234 (March 2018)




Proportionate regulation – the first principle abandoned in the age of harmonisation?

Proportionality is implied in the foundation of Australia’s principles-

based regulation.

In practice though, proportionality can be difficult to achieve. More often it

is the case that the regulatory requirements (and reporting requirements)

placed on large listed insurers are similarly required of the non-majors,

although APRA does strive to take into account the size, nature and

complexity of a regulated institution. It does not follow that the operational

sophistication of the majors needs to be replicated by the non-majors.

Harmonisation began in earnest in 2000 with the Financial Services Reforms.

General Insurance was first caught up in harmonised regulation that saw the

creation of AFSLs, PDSs, and general and personal advice.

Proportionate regulation has also become more difficult in a time of

greater cross-industry regulation. The trend in regulation over the past

decade has been of a ‘harmonisation’ of requirements across and within

industries. The idea may be simple, but the reality is not.

The responses to the failures of one part of the financial system are

increasingly borne by institutions in another part of the system (e.g. BEAR

legislation applying to insurance; self-assessments, following APRA’s

prudential inquiry into CBA; Actuarial Advice Framework required for

general insurers off the back of issues in the Life Insurance industry).

The pursuit of harmonisation has continued apace, without pause for

sufficient review of the benefits relative to the costs. Harmonisation may

simplify regulatory responsibility but carries with it the risk of unnecessary

interference in the operations of insurers and the creation of a culture

of grudging compliance. Regulatory harmonisation runs the real risk of

adding to the regulatory burden without clear benefit for the business,

the industry or policyholders.

Transparency and effective disclosure – was it ever thus?

A lack of consumer understanding or awareness is a common theme

running through the numerous inquiries into the financial system. Effective

and transparent disclosure and consumer understanding are issues that

the financial system has been grappling with for decades.

It is well accepted that there are limitations of financial literacy amongst

consumers and perhaps more fundamentally that there is widespread

disengagement by consumers regarding their insurance purchases.

Equally it is accepted that more disclosure is not necessarily effective

or transparent disclosure.

Wrapped up in these ideas is the demise of the concept of buyer-

beware, issues of operational pragmatism, the actual need for fine print

in insurance contracts, and the fact that the most common General

Insurance products are actually quite simple to understand.

These longstanding issues have been recognised by the Insurance

Council of Australia (ICA). In 2015, ICA’s Effective Disclosure Taskforce

recommended the revised Code of Practice include guidance for insurers

on best practice disclosure. In ICA’s Final Report: Review into General

Insurance Code of Practice (June 2018) (the Code Report), the ICA

supported the adoption of this recommendation.


The inevitable

Unfair contract terms

Unfair Contract Terms Legislation (UCTL) for consumer contracts was first

introduced in 2010. It was expanded to include small businesses (with less

than 20 employees) in late 2016. While financial products were captured in

the 2010 legislation, insurance products remained carved out. Removing the

carve-out for insurance was before parliament in 2013 but parliament was

prorogued shortly after.

Unfair contract terms legislation for insurance contracts is back on the agenda.

In December 2017 the government announced that it would extend UCTL

to include insurance. In August 2018, consultation closed on the exposure

draft legislation.

The industry response through the ICA has largely focused on the nuance

in the definition of the ‘main subject matter’ of a contract. The importance of

this legislation for insurers hinges on this definition. Should the government

adopt similar wording to the European or United Kingdom UCTL then the

impact will not be as significant as it would be if it persists with the proposed

narrow definition.

A simple example is a policy exclusion for wear and tear in a home insurance

policy. Is this exclusion unfair?

Response

Insurers should proceed on the basis that UCTL is unavoidable for retail and small business policyholders. The difference for insurers will come back to the definition adopted of ‘main subject matter’.

There are differing views about the likely burden of compliance with UCTL. Insurers may need to review the policy wordings of existing products, establish a process by which all future policy wordings are reviewed against UCTL obligations, update internal training for staff, engage with ASIC before, during and after implementation, and devote resources to investigate claims of unfair contract terms if and when they emerge.

That being said the impact of UCTL on insurers has been already absorbed by the UK and New Zealand markets. The Australian market for other retail financial products has absorbed the impact of UCTL since 2010.

For consumers, UCTL offers a more specific remedy than the duty of utmost good faith, and a remedy that is more easily enforced by a regulator.



Response

The significant issue for insurers is that the legislation, once in effect, is not proportional. Aside from some generalised motherhood statements, the information provided by Treasury on the draft legislation does not give lasting comfort that proportionality will win out over the detail of the proposal. And it is this detail that still attracts significant uncertainty for insurers.

To this point the definition of an appropriate TMD requires that a product sold to a consumer is “likely to be consistent with the likely objectives, financial situation and needs of the retail client”. We suspect this requirement has been framed with products other than General Insurance products in

mind. Can there be a narrower target market for comprehensive motor than people who own a car?

While there are examples of mis-selling (some consumer credit insurance and other add-on insurances) these are not the main General Insurance policies purchased by consumers. The TMDs for home and motor are necessarily broad, and so there is still some cautious hope for insurers.

While the FSI and draft legislation declaim the costs of any administration, the costs of compliance for insurers are likely not immaterial. We imagine insurers will need to: establish project teams and governance to introduce the obligations initially, engage with

ASIC, allocate product manager and executive time to make TMDs for every product, establish and operate a compliance process to review TMDs and confirm ‘reasonable steps’ were taken such that distribution is consistent with TMDs, amend existing contracts of distribution to reflect the greater responsibilities distributors and issuers owe each other, as well as change websites to include TMDs, which are required to be published. This process and the outputs are also likely to require external monitoring and legal sign-off.

Specifying, collecting and analysing the information to be provided by distributors will be a significant cost in some situations.

ASIC’s powers of intervention and how these will be used in practice are also uncertain. When and in respect of what types of products will ASIC intervene? How will this action shape actions of issuers and distributors?

From a consumer perspective, there is likely some benefit from this legislation, especially in respect of traditionally poor value products. The TMDs (if read by consumers) would in theory allow them to draw conclusions about the product’s relevance to their general financial situation and need for the product, but the consumers most vulnerable to buying an unsuitable product are generally those least likely to make use of a TMD document.

The inevitable

Design and Distribution Obligations and Product Intervention PowerIn July 2018 the Treasury released its second exposure draft legislation,

Design and Distribution Obligations and Product Intervention Power (DDO&PIP).

The legislation is an outcome of the Financial System Inquiry (2014) (FSI). The

draft legislation applies to all financial products that issue a product disclosure

statement (PDS) and is described as principles-based and aimed at promoting

the provision of suitable financial products to retail consumers.

The legislation is largely in response to issues of design and distribution of

complex wealth and other investment products. The FSI however, explicitly

referred to add-on insurance issues as a factor in its decision to ‘widen the

scope’ of its recommendation to include insurance.

The legislation details four design obligations and five distribution obligations.

The key points are:

• Issuers to make a target market determination (TMD) for a product

• Distributors to “take reasonable steps so that retail product distribution conduct is consistent with TMD”

• Distributors to collect information specified by issuer (including complaints), to ensure the TMD “remains appropriate”

• ASIC has new powers to ban products and both civil and criminal penalties apply to contraventions of the legislation.

The majority of retail General Insurance products are mass-market products, that

give consumers sufficient flexibility to tailor their cover to suit their circumstances

(through excesses, sums insured, optional extras, etc). The FSI envisioned

a relatively simple process for mass-market products, “compliance with this

obligation should be straightforward for simple products that are likely to be

suitable for most consumers.”



The inevitable

Deferred sales model and add-on insurance

For the General Insurance industry, add-on insurance has proven to be the

thorn in the lion’s paw. Add-on insurance (including CCI) represents less

than 2% of gross earned premium in the industry. Yet the failings in this

small segment continue to have repercussions for the entire industry.

For some insurers, provision of these products, with the associated

commissions and incentives, has been part of a strategy to access the CTP and

comprehensive motor markets delivered by the car dealer networks. For many

dealers, these commissions were essential to their business model, resulting in

a market distortion that left consumers with either poor value or unnecessary

cover. The attention of ASIC has resulted in the financial remediation of

policyholders to the tune of $130 million so far.

It has never been clear to us whether the concerns about consumer outcomes

are concerns about the insurance and finance sectors or really concerns about

the culture, standards and behaviours in the car dealer market. Much more

of the profit from sale of these products has accrued to different parts of the

distribution chain rather than to the insurers. Nevertheless ASIC has focused

its attention on the insurers and will continue to do so.

ASIC recommends the introduction of a deferred sales model (DSM) for add-

on insurance and warranty products. Under the proposal, there is a minimum

deferral period of four days, which consumers cannot opt out of.

Response

The impact of the DSM is limited to insurers that sell add-on insurance. For other insurers, it is a case of not much to see here.

For some insurers the regulatory and reputation issues seem to be outweighing any financial benefit and they are simply withdrawing from this market. To the extent that relationships with dealer networks remain relevant to their other business lines, different tactical approaches will be needed.

For insurers choosing to remain in this segment, in one way or another, the DSM will be one of the main challenges, but not the only one. It seems most unlikely that the distortive remuneration practices demanded by dealer networks can endure in the new landscape. Car dealers will have to come to terms with much lower remuneration from product sales as well as tougher compliance standards.

It may well be that the DDO&PIP legislation (discussed on the previous page) is a more effective response than DSM (or in conjunction with DSM).

A useful starting point for insurers would be the work done by the ICA in respect of poor value products and the adoption and development of a governance structure around poor value products by each insurer. There are many regulatory options open at present, so it is not clear whether this direction would be seen as acceptable by stakeholders.



The inevitable

AFCA

From 1 November 2018, the Australian Financial Complaints Authority (AFCA)

will become the single external independent dispute resolution service for

the financial system, replacing the Financial Ombudsman Service, the Credit

and Investments Ombudsman, and the Superannuation Complaints Tribunal.

Monetary limits for disputes heard before AFCA have doubled, from $0.5

million to $1 million, with compensation capped at $0.5 million (for disputes

not related to superannuation).

Response

The likely immediate impact on general insurers will be operational – customer communication, standard letters, systems and procedures – which in the current regulatory environment feels like a cost to insurers for little business or consumer value.

It would be reasonable to expect that the methodologies used and outcomes arising from AFCA would not be much different from FOS. Nonetheless the risk of unintended consequences always arises when there is a change of this kind, as well as the risk of operational failures and delays. With the current turbulent environment one risk is that AFCA starts with a much more zealous approach than its predecessor organisations.

Putting the new scheme in context, very few General Insurance claims (relative to the volume of claim reports) make it to FOS and almost half of all FOS disputes, across all industries, are resolved directly with the financial institution. AFCA’s revised monetary limits are unlikely to affect insurers materially – FOS previously had the power to remedy claim amounts from General Insurance claims, and few retail and small business claims reach the $0.5 million mark.

General Insurance Code of Practice

The General Insurance Code of Practice has been reviewed by the Code

Governance Committee. The ICA’s response to this review was published

in June 2018. Suggested are new obligations for consumers experiencing

vulnerability, financial hardship, new requirements on Family Violence and new

guidance on mental health.

Response

Prior to the inclusion in the code of practice, many insurers would have had their own formal or informal ways of approaching these types of issues. Inclusion in the code is recognition by the industry of the differences among consumers and their needs at particular times.

The initiatives may be worthwhile but will require effort by insurers to develop practices, processes and train staff to meet the new obligations and requirements. There are limits to the practicality of some of the new Code provisions and much relies on the self-identification by consumers to insurers at the point of sale or claim.

One of the Uncertain environmental issues discussed in the next section is how the Code is applied. The landscape will look very different to the extent that the Code is incorporated into law and sanctions applied.




The inevitable

Draft APRA Prudential Standard on Information Security

On 7 March 2018, APRA launched a new a consultation period for the industry to

review and provide feedback on a draft information security standard CPS 234.

This new APRA prudential standard will require regulated entities to:

• Clearly define the information security-related roles and responsibilities of the

board, senior management, governing bodies and individuals;

• Maintain information security capability commensurate with the size and

extent of threats to information assets, and which enables the continued

sound operation of the entity;

• Implement information security controls to protect its information assets, and

undertake systematic testing and assurance regarding the effectiveness of

those controls;

• Have robust mechanisms in place to detect and respond to information

security incidents in a timely manner; and

• Notify APRA of material information security incidents (within 24 hours after

experiencing such an event).

The consultation period was open for three months until 7 June 2018. APRA

intends to finalise the proposed standard by December 2018 and to implement

the new standard from 1 July 2019.

Response

From a compliance perspective, APRA expects that information security risks will have the same visibility as other risks contained in an entity’s Risk Management Framework and other required elements of CPS220.

It forms part of a wider APRA project to update the qualitative management of operational risk across all APRA regulated entities.


The uncertain

An indirect focus on pricing – or ongoing issues of affordability, insurability and transparency

The display of last year’s premium on renewal noticesThe display of last year’s premium on renewal notices is a proposal endorsed

by the Senate Economics References Committee in their report, Australia’s

general insurance industry: sapping consumers of the will to compare (2017),

and one also recommended by the Productivity Commission (PC) in its Inquiry

into Competition in the Financial System (2018).

Keeping in mind that the additional provision of information to consumers

has not proven a success in and of itself in the past, the immediate question

for insurers becomes: what is the level of responsibility of insurers to explain

changes in premium and what is their scope to do this?

Response

Far be it for an actuary to politely point out that the bald comparison of two numbers is often not as straightforward as it may sound. There are myriad reasons (some straightforward, some complex, some

related specifically to the insured, some related to the market, some related to the insurer’s pricing strategy) for an insured’s premium to be different on renewal.

This means that beyond changes to systems, renewal letters, and other operational processes, there will be additional ongoing resources required from actuarial teams and product managers, as well as training for call centre and front-line staff. The compliance function will then need to verify that the information and the responses to customer queries are correct.

The ICA in their Final Report: Review of the General Insurance Code of Practice (June 2018) have recommended that the Code be amended to include an obligation for insurers to disclose the previous year’s premium on renewal for home insurance policies. In addition, it has been recommended that the Code be amended to require consumers be given access to a sum insured calculator when purchasing home insurance.

Component pricingThe Senate Economics References Committee recommended a review into

component pricing, and the Australian Competition and Consumer Commission

focuses on ‘key components of insurance’ in its issues paper outlining areas of

inquiry in the Northern Australia review.

Though often only vaguely defined by its proponents, we take component

pricing to mean the breakdown of a premium into the broad groups of:

claims costs (possibly split by natural perils and non-natural perils), expenses

(possibly with reinsurance expenses separately shown), taxes and profit

margin. Again notionally the aim is to provide more information for consumers,

particularly consumers in natural peril affected regions. Again though, the idea

is not as simple as it is appealing.

Response

It is unclear how governments will respond to the idea of component

pricing. In response to the Senate report, the government has commissioned further review from Treasury. At the time of writing, we have no information about where this stands.

Nevertheless should something like component pricing be introduced, we imagine the impact on insurers would be considerable, and the benefits to consumers small. Renewal procedures, quote engines, and websites would have to change; there would need to be ongoing input from product managers, actuarial teams, IT and marketing, training for front-line staff, as well as information for consumers on how to interpret the information. And this all begs the question of whether it will help consumers make better decisions?



The uncertain

An indirect focus on pricing – or ongoing issues of affordability, insurability and transparency

Price optimisation of the individual offering

The last decade has seen an increase in the sophistication of insurers’ ability

to price and segment risks. Judgement and pricing strategy have always

provided some overlay from technical to market premium rates, and insurers

have generally tried to incorporate a degree of smoothing during rate transitions

to maintain policyholder retention levels. This has historically occurred at a

broad segment level.

There are a number of definitions of ‘price optimisation’. The American Casualty

Actuarial and Statistical (C) Task Force in their Price Optimization White Paper

(November 2015), step through a number of these definitions including this one

from the American Academy of Actuaries’ Price Optimization Task Force, where

price optimisation is defined as:

“…a sophisticated technique based on predictive modelling results and business

objectives and constraints that are intended to assist insurance companies in

setting prices. It is an additional component of the pricing process in which the

business manager goes from cost-based rates to final prices by integrating

expected costs with expected consumer demand behaviours, subject to target

business objective(s). The target business objective(s) may be to improve profit,

increase volume, increase or maintain retention, or some combination thereof.

These targeted business objectives represent the insurer’s pricing strategy.

Price optimization is a technique used to achieve that pricing strategy.”

Put more simply, price optimisation at the individual consumer level means that

consumers with the same risk profile may be priced differently by the same

insurer based on their expected price sensitivity or on other factors distinct from

their risk profile.

There is a serious economic paradox underneath these issues. Insurers (as

with other commercial entities) want to attract new business. Attractive pricing

is part of the strategy. But it is well known that the expenses required to acquire

a policy of new business are far greater than those required to renew a policy.

With 12 month renewable policies, how can this paradox be resolved by

premium setting?

Response

Insurers in Australia set their own prices, subject to their own internal and external market constraints. Technical or expected claims costs remain the foundation of insurance premiums.

Consumers’ level of awareness of price optimisation is likely low. There is a wide expectation amongst consumers that insurance premiums reflect differences in expected costs between different risks. Price optimisation moves insurance pricing beyond expected costs to expected behaviour around price sensitivity.

There are existing mitigants to the optimisation of individual consumers: a competitive market (which the General Insurance market broadly is) should ‘compete away’ differences in price between different insurers for the same risk; it is reasonably straightforward for consumers to compare prices between insurers and there are few frictional costs for consumers (other than their own time) in switching between insurers at the point of renewal. These mitigants in reality however, may be less effective than the economic theory suggests, particularly when faced with the low level of consumer understanding and low level of consumer engagement with insurance purchases in the Australian market.

The practice has come under some scrutiny internationally. For example some state-based insurance regulators in the United States have tried to explicitly ban price optimisation using their powers to regulate home and motor premiums.

It is important that insurers are sensitive to this issue, including in the representations made to current and potential future customers.



The uncertain

APRA’s prudential inquiry into CBA

In July 2018 APRA published its report Prudential Inquiry into the Commonwealth

Bank of Australia. The report made 35 recommendations in areas of

governance, accountability and culture. The report received significant attention,

with then-Treasurer Morrison calling it required reading for Boards of every

financial institution.

The executive summary was ripe with quotable phrases: “clear and present

danger”, “chronic unease”, “drip, by corrosive drip”, “financial success dulled the

senses of the institution”, and the “voices” of the risk function and consumers

“did not always ring loudly”.

The report has weight and reach. Following its release APRA made clear that all

large regulated institutions (not just banks) were to conduct a self-assessment

against the issues identified. Furthermore, APRA has indicated that it will form

part of the toolkit for frontline supervision of smaller companies, with a particular

emphasis on whether there is sufficient and effective challenge to business

decisions from frontline operations as well as the risk and compliance function.

Response

There are real and significant uncertainties for insurers, especially small and medium-sized insurers, in trying to discern the possible impact of this inquiry on their business. Against the backdrop of the Royal Commission, and in the context of the existing (and comprehensive) requirements of Boards and their governance, it is difficult to come to grips with APRA’s extrapolation of a prudential inquiry into the CBA’s culture and governance to all regulated institutions.

The immediate cost to insurers will be time – management and Board time in preparing and conducting self-assessments and engaging with APRA. And to the extent that the self-assessments yield areas for improvement, resources will be required to address these. These resources could well be significant. It should not be forgotten that the CBA also incurred a financial ‘penalty’ – a supervisory capital adjustment of $1 billion.

BEAR legislation

In July 2018, the Banking Executive Accountability Regime (BEAR) legislation

was introduced. It requires Authorised Deposit-taking Institutions (ADIs) to

specifically detail the responsibilities and reporting lines of Accountable

Persons and to notify APRA of these arrangements. The legislation opens

senior executives to civil proceedings and gives APRA the power to deregister

and disqualify executives. It also prescribes requirements around executive

remuneration, which can be reduced in respect of conduct issues.

BEAR applies to the subsidiaries owned by ADIs, which includes some insurers.

Response

Separate to insurers owned by banks, BEAR is another example of specific legislation or action in one part of the financial system potentially rippling and capturing General Insurance in its wake.

It is not beyond the realm of reason to see this legislation extended to other industries in the financial system. It is attractive to regulators as a pre-existing means by which they can increase and enforce accountability in financial institutions. The UK operates a model similar to BEAR, which was extended to cover wealth and asset managers in 2018.

The success of BEAR in promoting a more accountable banking industry in Australia is yet to be demonstrated, although it is clear that the effort of implementing and complying with BEAR for ADIs is material, and the scope to extend the legislation is real.




The uncertain

Hayne Royal Commission – Insurance hearings

For general insurers the Royal Commission’s public hearings did not uncover

systemic issues or new examples of poor conduct or misconduct. The case

studies trod a well-worn path through the problems of add-on insurance,

claims handling post-natural disasters and weak risk and compliance cultures.

On 28 September Commissioner Hayne published his Interim Report.

While this report did not get as far as superannuation or insurance the

key messages are clear:

• Greed is the root cause of the misconduct identified

• New laws will not help

• Maybe laws should be simplified

• Enforcement needs to change.

Commissioner Hayne suggests that ASIC should be a more aggressive regulator,

bringing civil charges and litigating more frequently.

The risk for insurers remains becoming caught in the regulatory pull as

other parts of the financial system come to terms with the impacts of the

Royal Commission.

A final thought

Amidst the tumult of this still changing, still uncertain regulatory landscape,

insurers still need to go about their core business.

Many companies have acknowledged privately the extent to which the

regulatory turbulence has distracted the focus of Board and senior management

from the core business. Nevertheless it is real and important, so each entity

must work out approaches that recognise the uncertain landscape without

inadvertently destroying value in their business.

To use a metaphor (perhaps a poor one), some turbulent weather has resulted

in a tornado that is picking up objects in its path and spinning them around.

At some point the storm will pass and the tornado will have dropped its cargo

into a new and unpredictable landscape. Until then the best approach would

seem to be to work on resilience and preparedness rather than moving straight

into ‘disaster recovery’.

Insurers will need to take the Inevitable changes in their stride. With so much still

in the ‘uncertain’ bucket, there are some insurers (and their industry body) with

the need and capacity to try to influence the outcomes.

For all, the challenge remains to make some sense of this chaotic

regulatory landscape and to deal with it in a coherent way within

the resources at its disposal.


Carmen BurrastonGeoff Atkins

Please contact: [email protected] or [email protected] further information about this article.

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Optima - Actuarial and Insurance Consultants€¦ · beware, issues of operational pragmatism, the actual need for fine print in insurance contracts, and the fact that the most common