Insurance Ireland response to Central Bank's Consumer Protection Code Review (CP158)


With a formal written response running to almost 40 pages, following numerous member events and bilateral meetings with the Central Bank of Ireland, Insurance Ireland has submitted comments on behalf of the Irish Insurance sector to the CBI on the consultation relating to the Consumer Protection Code (CPC). With 427 proposed text changes to the existing CPC, 232 replacements, 115 insertions and 90 deletions, there was plenty of material for the II team to review and consider with our members. Some of our points are set out below, but many more specific issues have been raised in our formal submission, which we look forward to discussing in detail with the CBI over the coming weeks prior to any feedback being issued.

The submission is in two main parts:

  • Response to questions in the consultation paper
  • Appendix setting out comments and issues with specific draft regulations and the potential impact on consumers of insurance products.

Overall, we agree that the review of the CPC is a timely exercise. The Code has, since its introduction in 2006, been the key point of reference for industry and consumers in setting the expectations and rules around fair treatment of consumers of financial services.  However, technology has evolved and as a result, so have consumer expectations when interacting with insurance providers. Regulation must keep pace with this evolution. We are also appreciative of the overarching goals of the Code review - which are to provide more clarity, predictability and consistency on the consumer protection obligations of financial services providers.

As the Central Bank will no doubt appreciate following the consultation process, the wholescale review and update of the fundamental rules by which financial services firms are bound by when dealing with Irish consumers is an extremely time-consuming and resource-intensive exercise, from a detailed review of the individual specific regulatory requirements by both the CBI and the industry, to implementing the required resulting changes and ensuring that firms adapt and enhance the systems, policies and procedures to meet the regulatory obligations in this space.

The consultation sets out a number of significant proposed changes across a number of areas of the Code around timelines, requirements for written confirmation (both from a provider and from a consumer) and introduction of a number of new information disclosures that must be issued to the consumer as part of the customer journey in advance of, or after, the acceptance of a policy as well as other compliance requirements with the Code. This results in a material impact on the consumer journey and increased compliance costs in adhering to regulatory obligations, which are ultimately borne by the consumer. Some proposed subtle wording changes have been identified, which were not highlighted in the CBI’s over-arching consultation or the helpful Mapping Tool and will have significant impacts on insurance firms. It is vital that the consumer should benefit from these, and that any potential consumer detriment is minimised in the practical implementation of the proposals.

Read the summary of Insurance Ireland's response below.

Insurance Ireland summary response to CBI CP158

Format: PDF File Size: 435.82kB

Insurance Ireland summary response to CBI CP158

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