The Financial Services Authority has announced its intention to launch a market study into how pure protection insurance products are sold, following concerns that competition is not working well in the market.
Pure protection products are designed to help individuals and their families with their finances should the policyholder die or become unable to meet their financial commitments.
Around £4 billion was paid out in claims in 2022. The products are mainly sold through intermediaries like independent financial advisers or mortgage brokers.
The FCA has raised concerns that the design of commission arrangements “may not allow firms to deliver good outcomes to policyholders”.
The regulator is also concerned that some products may be providing poor value, for example if the total premiums paid over a lifetime far exceed the maximum conceivable payout.
The study will explore consumers’ engagement with and understanding of the products they are buying, the competitive constraints on insurers and intermediaries, and potential conflicts of interest in the structure of commission.
The FCA will focus primarily on the sale of four specific types of products: Term assurance, critical illness cover, income protection insurance and whole of life insurance including policies for over 50s that offer guaranteed acceptance.
Ian McKenna, Protection Guru founder and CEO called the review “unprecedented and highly welcomed.
He said: “This review is long overdue, as there has not been such an in-depth examination since the introduction of the 1986 Financial Services Act. The protection market has evolved significantly, and while it operates more efficiently in many areas than it has in the past 38 years, there are still crucial areas that need regulatory attention.”
He pointed to several key issues that he believes “require the FCA’s careful consideration”.
These include inconsistencies around terminal illness benefits and the challenges in accessing information, “equally post-COVID a scarcity of qualified claims adjusters has led to delays in claim payments, an issue highlighted by the Protection Distributors Group through their work on the claims charter.
“The FCA should certainly look at why there is such a large disparity between the level of claims paid on individual protection plans and group risk where in the case of Group Income Protection and Group Critical Illness far fewer claims get paid. It is noticeable that when information on the group risk market is published annually invariably it focuses on premiums received with barely any reference to claims paid. Group risk cover has seen major growth in recent years – have claims kept pace?”
McKenna added that the UK protection market currently faces a lack of supply, with several consolidations in recent years “significantly impacting consumer choice”.
“We are now left with only a handful of insurers operating in certain sectors. It is vital that the FCA avoids any actions that could lead to further contraction in the number of providers, as this would severely damage competition. It would be great to see the regulator focus on making the UK market more attractive for new insurers to enter, thereby enhancing competition and consumer choice.”
McKenna said the UK protection market offers superior products at highly competitive prices compared to other major economies and is also far more efficient than other jurisdictions. He pointed to the United Stated, “where it still takes months to get most policies in force which leads to significant consumer detriment”. Also to recent changes to regulation in Australia, which he says, “have led to poor consumer outcomes and a major reduction in the number of people protected.
“The FCA need to be very careful not to make the same mistakes. However, recent changes to capital requirements have made it difficult for insurers to profitably offer plans to consumers requiring any level of rating. If the FCA does not tread carefully, millions could become uninsurable. The UK must remain an attractive place for insurers to write pure protection business to maintain the high standard of products available.”
With Consumer duty largely focussed on wealth advisers, protection advisers have been left with less clarity on expectations, although the recent thematic review emphasised that advisers basing recommendations solely on price are not meeting the new standards.
“This review presents an opportunity for the FCA to provide more guidance on what is required from protection advisers,” McKenna said. “Many advice firms are already working towards significant changes, and it is hoped that the FCA will recognise these efforts and target actions at those who are not yet adapting.
“While there is room for improvement, the UK protection market is on a positive trajectory, particularly with the recent boom in income protection sales. It is crucial that the FCA’s review supports this momentum without causing unintended setbacks. The industry now has the chance to build an even better protection market for the future, and we look forward to working with the regulator to achieve this goal.”
