Oireachtas Joint and Select Committees

Wednesday, 7 September 2016

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach

Rising Cost of Motor Insurance: Minister of State

11:00 am

Photo of Eoghan MurphyEoghan Murphy (Dublin Bay South, Fine Gael)
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As the committee engages with other stakeholders, it will get a chance to tease out several issues. This is an urgent issue. We have to be responsible in how we manage public expectation because there is much work that has to be done and can be done. I want to ensure we can see what those early priority actions are so we can get moving on this. If we can do that with consensus, it will pre-empt any potential increases in premiums in the coming months. I know the Chairman, Deputy John McGuinness, Deputies Michael McGrath and Pearse Doherty and others have been raising this issue. It is an important issue up and down the country. The Minister for Finance, Deputy Michael Noonan, has been taking it seriously for the past year. That is why he established the task force. Its first port of call was to look at compensation in the industry itself. That is the work it began with to ensure there was a proper structure in place. The second piece of work that had to be done by the task force was in respect of flood insurance. A report is with the Office of Public Works, OPW, which will be published soon.

The next task was to move to the increasing cost of motor insurance. The real spike happened in the past 12 months to July and was approximately 40%. An important thing the Minister did was to give political direction to this by making it one of my delegated responsibilities as Minister of State in the Department of Finance. This has allowed a working group emerge and get work done. It highlights the importance the Government places on this.

The impression that work is not going on behind the scenes and between meetings would be a false one. We all know, as people who work on various issues and as part of our job to attend meetings, that we work hard in between meetings. We needed to ensure we had all the relevant stakeholders in the room. The next point was to ensure we had robust terms of reference that would get the job done quickly. We then had to ensure we would be engaging with the right elements of the industry and different stakeholders so we would have a clear picture and be able to build consensus.

We have not been coming at this from a standing start either. Of course, several streams, such as legislative measures, uses of new technology or tackling particular issues, have been examined in the past 12 months or more. Part of the work I have to do with the working group is to see what the priorities are, bring them from the centre and get them done.

There is a real problem with transparency with easy and early settlements in the industry which have been raised. Up to 20% of cases are settled through the Injuries Board and 10% through the courts. That means there are 70% of cases where we are not sure what is happening. Are they being settled before they go into the Injuries Board or afterwards? What quantum is involved? How long is the settlement taking? What other costs are incurred? What level of claims are being given out? We definitely need more transparency in that area.

While we need respect for privacy and data protection laws, the sharing of data between the NCT, insurance and tax agencies with the Garda Síochána and other relevant bodies should be happening and should be easier. I hope we can build consensus, through the committee’s engagement with the various stakeholders and my working group’s engagement, so that easy measures could be introduced quickly. From some of my informal engagements so far with different elements of the industry, matters in database development are not proceeding as quickly as they should be.

There needs to be a big push politically. That is a big push I am willing to give but I need support in that regard to ensure the industry is on board and working with us.

From the informal engagements I have had to date, there is not necessarily consensus on what is driving up premiums. The committee will hear that as well from the different people who appear before it, who will be making different claims as to what is driving up costs. We are going to have to decide which is correct and which is not. We need to take the standard insurance premium, if there is such a thing anymore, and break down its constituent costs. For example, is €50 is being added on to premiums for fraud or €35 for uninsured drivers? How much is because of early settlements or fear of litigation? How is that affecting premiums and what levers do we pull to address that?

My intention is to have a detailed understanding and roadmap by October for the Minister for Finance, Deputy Michael Noonan, showing exactly where we need to go. Between October and the beginning of December, I intend to put in place an agreed action plan that has buy-in from everyone. If we want to get this done in a meaningful way for consumers, we are going to need to ensure there is a consensus and buy-in at the very beginning. Much of that work is already progressing. We had a second plenary meeting recently but much work was done between the two plenaries. There is a busy schedule of meetings between now and the middle of October and then through to December, when we hope to have a formal report and action plan ready. Some things will happen sooner, such as the book of quantum. I will let the Injuries Board speak more on that because it is more appropriate. It will explain the changes with the new book of quantum, which will help with the information that is being provided to the Judiciary. Measures such as an enhanced renewal notification process need to be examined and will be on our side. Reform of the Injuries Board is also being examined. That work has already begun. It is about deciding the medium and long-term actions that can be taken. For example, if we want to give a greater legal weight to the documentation that appears before the Injuries Board, then that might be a longer-term issue. However, we could look at statutory timelines with medical appointments. For example, if one does not attend a medical appointment within nine months, then one automatically falls out of the Injuries Board and the case can go to court. Can we look at ways of pausing that timeline so that it cannot be the case that people who just miss a medical appointment are out of the Injuries Board? It is alleged to me that people sometimes intentionally fall out of the process because they believe they can get a better settlement in the courts or after the Injuries Board.

The industry will have much to say about costs. Different companies in the industry will have varying perspectives on that too. On increases in safety, the AA will explain improvements in technology and telematics. My understanding is that more work is needed in this area. Some good work has been done but it is not there yet in terms of having standard telematics built into every car which cannot be tampered with easily. It may become an opt-in for the driver to get a lower premium. The AA has conducted surveys among its own members on this. I believe it was surprised by the results but I will allow the committee to ask it in more detail. I thought telematics technology might be a quicker route but my understanding is that it will take a little bit longer to actually put it to good use. It is a solution. We must bear in mind that the motor industry will change dramatically over the next five years. We have already seen this with self-driving cars and in enforcement areas.

The relationship between insurance companies and body repair shops is an interesting question.

I will ensure that we look at it and I would like the committee to put it to the industry groups publically - I will be putting it to them privately.

The issue relating to insurance staff has been highlighted to me by some industry players. I hope the committee will be talking to those players because, although I cannot speak for them, I believe they would also have some interesting observations on the points raised.

Deputy Sherlock referred to a number of issues. In order to be clear, I reiterate that I was asked to examine the areas of non-life insurance but I very much wanted to focus on motor insurance because so many colleagues have been raising the matter with me, as have my own constituents. People who have done nothing wrong this year compared to last year - no penalty points, no accidents and no changes to their vehicles, which might only be one year older and have passed the NCT - were hit with hikes of 40% and more in their insurance premiums in the 12 months to July. This situation is not acceptable and it is the reason something must be done. The price cannot be set and regard must be had for the stability of the sector. In addition, there should be no unintended consequences to our actions. While we must move quickly and together, we need to be conscious of them impact of anything we might do. I give as an example the suggestion by one industry player that if a move was immediately made to engage in a data dump in respect of all claims settlements made outside of the PIAB and the courts system, the unintended consequence might be to drive premiums up if people became aware of the awards being made in respect of certain injuries. We absolutely need transparency but we must plan our work carefully in order that it will not have any negative effect in the context of what we are trying to do, which is to try to maintain some sort of control over the rising costs of motor insurance and to work to bring the cost of premiums down.

Provisioning was too low and I believe the representatives from Central Bank will speak to that when they come before the committee. Evidence seen by the committee shows that profits have not been made in recent years by any of the main players operating in the market. They are now moving to correct that position but there is risk of an overcorrection. If more market participants could be brought in from abroad, then a better idea of the actual state of the market might become evident. However, there is a reluctance for foreign competitors to become involved due to a lack of transparency in the market as a result of data not being shared on foot of concerns regarding fraud and uninsured drivers and, if we are to be honest about it, market failure.

The price of insurance cannot be set but we can examine the factors that make up premiums and tackle those various levers. For example, a breakdown of what makes up a premium would be helpful. The insurance industry is saying that €50 of each premium relates to the costs of fraud. Therefore, if it were possible to come up with a national claims database - I believe it would be possible to do so - I would hope that this would immediately reduce the need to provision for €50 on the price of a premium because of fraud. Greater levels of technology could be introduced to allow sharing of information between An Garda Síochána, the Motor Insurers Bureau of Ireland, the NCT provider and the motor tax office. We should be able to use cameras - as is the case in other jurisdictions - to record number plates and give the Garda all the relevant information it requires. This would mean it would be almost impossible to drive an uninsured vehicle on the road. If that was the case, then another €35 might come off the cost of premiums. These are small amounts compared to the significant sums people are paying for premiums and I reiterate that we cannot set the price. However, we can identify the component parts that would seem to be increasing premiums and we could start to use policy levers to tackle them. Much of that work has already been identified but one will find that there is no consensus about what needs to be done first or how quickly things can be done. That is what the committee needs to establish.

I have met industry players. I have also representatives from the brokers' associations on an informal basis. We will also engage with the latter formally in the context of the sub-groups. There is no evidence that has been brought to my attention - although it might be raised with the committee - of players entering the Irish market and making money off the back of Irish citizens and the premium rates that apply in order to make a quick profit. We have not seen evidence of that. If there is evidence, however, then it is important that it be made public. Legislation can be introduced in respect of fraud, data sharing, transparency, the injuries board and claims. If we are going to be bold, we can legislate in respect of new areas if radical ideas are put forward. There is an idea floating around regarding the concept of "care instead of cash". I understand the downsides of moving towards a care-instead-of-cash model. One negative would be the moving of costs incurred by the legal profession to the medical profession. However, under a care-instead-of-cash model, one could drive down what might be seen as excessive costs - in comparison with those which obtain in other jurisdictions - for injuries such as whiplash. One would certainly move fraud out from that part of the insurance system. If radical change is needed, it will require work and it would not be a short-term solution. We need to understand that we can still build around it as a longer-term solution if there is consensus on it. We need buy-in and we need consensus.

Senator O'Donnell highlighted some good examples of prohibitive rates. The Senator is correct when he says this cannot continue and that is why we treat the issue with such urgency.

The Senator asked questions on Setanta Insurance and Enterprise Insurance. I have some details noted with which to update the Senator on the current position with Enterprise Insurance. It is a developing situation. As Deputy Doherty has said, Enterprise Insurance is a Gibraltar-incorporated company under supervision in Gibraltar by the Financial Services Commission there. Enterprise Insurance sold motor insurance in a number of European countries, including Ireland, on a freedom of service basis. Wrightway Underwriting Limited - a retail intermediary regulated in Ireland - acted as the managing general agent and sold private motor insurance policies on behalf of Enterprise Insurance via the Irish broker network. The Gibraltar regulator notified the Central Bank of Ireland on Friday 22 July 2016 that it was taking steps, with the co-operation of Enterprise Insurance, to petition for the winding up of Enterprise Insurance. Enterprise Insurance had told them that the company was insolvent and had been unable to secure additional funding. At the time the provisional liquidator was appointed to Enterprise Insurance - Monday, 25 July 2016 - there were approximately 14,200 Irish private motor policyholders. In response to the appointment of the provisional liquidator Wrightway Underwriting agreed to refund unexpired premiums to next renewal for policyholders and started actively working with its brokers to find alternative cover for Enterprise's Irish policyholders. Since then the original figure of 14,200 policies has decreased to approximately 2,200, and this remains a work in progress for Wrightway Underwriting and its broker network. I realise that the committee would like to have a clearer picture of the position in relation to claims but I would be hesitant to provide figures that are not yet confirmed. The full picture of the financial position of Enterprise Insurance will remain unclear until the liquidator is appointed on a permanent basis, which is due to happen this month. The Central Bank is in close contact with Wrightway Underwriting on this matter. Other EU and EEA member states affected are the UK, with some 500,000 policies, Greece, with some 100,000 policies, and France, Italy and Norway, with a smaller number of policies.

With regard to the up-to-date position of Setanta Insurance, the situation with regard to payment of the first Setanta compensation payments is not yet clear. The Setanta case is awaiting the outcome of an appeal to the Supreme Court in the case of the Law Society of Ireland v. the Motor Insurance Bureau of Ireland. This will be heard on 24 October 2016. It may well be 2017 before the Supreme Court decision is delivered. On 4 September 2015 the High Court held that MIBI was liable in respect of claims against the Setanta policyholders. This decision was subsequently appealed by the MIBI, as the committee knows, and the Court of Appeal upheld the High Court decision in this case. MIBI was granted leave to appeal the decision to the Supreme Court, which is now happening. These potential MIBI payments relate to third-party motor insurance claims only, and the insurance compensation fund is liable for a further small number of additional claims. These are currently being processed by the office Office of the Accountant at the Courts of Justice. These claims are not as significant, as the bulk of the claims are third party motor insurance. The liquidation of an insurance company is a legally complex process. As Setanta Insurance was incorporated in Malta, the liquidation is being carried out under Maltese law. The Setanta liquidator has informed me that the number of open claims stands at approximately 1,700. The claims-reserved position stands at between €87.7 million and €95.2 million. Setanta policies were cancelled in May 2014, so the two years allowable under the statute of limitations within which to lodge claims has expired. This means that claims' figures will not increase further. However, final settlements can only be paid out by the liquidator after all the company's liabilities are quantified, including claims. Since the liquidator will not be in a position to pay out more than 30% of the claims, if the Supreme Court rules in favour MIBI, an insurance compensation fund may begin paying out 65% of eligible claims. The Law Society v.the Motor Insurance Bureau of Ireland court case has significantly delayed the process and the liquidator has reported that it is proving very difficult to settle claims in advance of the outcome of the MIBI appeal. I would expect to be in a better position to inform the House after the legal proceedings are concluded and the implications of the outcome have been assessed. That is the up-to-date position on both of those companies.

With regard to when I hope our report will be ready, as I have said, there will be an interim update to the Minister for Finance in October. At that point, if this committee has concluded its work and provided some sort of consensus on what the actual problems are and how to move on them, that will feed in to our own work and we will have a clearer idea for the Minister for Finance. We can then spend the remainder of October and November building a road map and an action plan to agree in December in order to put it to work. In the interim, certain things will happen; I understand the book of quantum will be published quite soon. There may have been a couple of weeks' delay, but it will have happened in the interim. We are already looking at the use of technology for detecting fraud or uninsured drivers, or the use of legislation to give more powers to the Personal Injuries Assessment Board. These will continue to be progressed.

They will not wait for our action plans which will, I hope, affirm that we will move to do that in any case.

The Central Bank holds a large amount of data. One of the subgroups will do a gap analysis and the Central Bank is working on that subgroup to help identify what data we are missing, what data it has and how these date could be released in a way that would be useful and would not undermine the bank's role as the regulator of the industry or the confidentiality of different agreements. The Central Bank is involved in work in that regard.

Senator Kieran O'Donnell also referred to awards made outside of court. I noted that 70% of the awards are being processed outside of court, with a further 20% processed through the Injuries Board. The board will probably make the case that the whole purpose of establishing it under a previous process concluded in the early 2000s was to avoid litigation. If litigation is avoided in 90% of cases, the board is doing its job in one sense. However, the Injuries Board will also note the lack of transparency in respect of the 70% of cases that are being settled outside of court and issues such as the point at which they are being settled in the system, the way in which they are being settled, the length of time it is taking to settle them and other costs arising in such cases. It will call for transparency, as I and others have done. However, this is not a discussion we are having because there is no point in having the joint committee hold a series of robust and vigorous meetings and produce a report and having a working group holding similar meetings, albeit in private. We are trying to ensure that, as the work progresses on both fronts, the levers of government are used to identify what precisely can be done and what actions can be taken. This is not about producing a report that will sit on a shelf but about drawing up an action plan and getting something done. Members of the public will not stand for what is happening and we must be responsible in responding to the issue collectively.

Senator Conway-Walsh raised a number of issues and spoke extensively about transparency. She is absolutely right that we will meet resistance. The joint committee will meet resistance from the various stakeholders when they appear before it because I have met such resistance in private, although it may not be so evident in public. A hell of a lot of information is available and it is being used in other jurisdictions. Companies operating in this jurisdiction share data in all sorts of ways publicly in other jurisdictions. It is unacceptable that such data sharing is not taking place here. We must ensure we plan our work with the industry to ensure this issue progresses. The joint committee will have another opportunity to discuss this issue with AA Ireland and other organisations which have been talking about it a great deal.

The stability of the insurance market is key. We must protect ourselves from further market failures, ensure consumers are protected and prevent further unforeseen and unmanageable spikes in insurance premiums. As I stated, this is not about washing our hands of our ability to set prices. However, we must make clear to members of the public that we cannot set prices. We must manage expectations because we cannot require insurance providers to charge X amount for premiums. Insurance companies must taken into account provisioning requirements and Solvency II compliance. They set prices based on risk. The work everyone has been doing on this issue in recent months has been informed by people setting out their perceptions of what they are encountering and the engagements they have had. Deputy Pearse Doherty, for example, spoke about his experience of trying to elicit more information. We know from this work that different steps can be taken to influence how premiums are set. We must then try to drive proper structural reforms because there will be no point revisiting this issue five years from now. Proper structural reforms are needed to ensure we have a properly functioning motor insurance sector. That is the outcome we must achieve and if we structure the process in a short, medium and long term, we will achieve it. The joint committee has an important role in helping to set the agenda and build consensus by discussing the various issues that are coming to the table and I do not want to pre-empt any of that work.

I will consider the possibility of providing our interim report to the committee. While I do not envisage any problem with doing so, I would first like to discuss the matter with the Minister for Finance. If we are to address this issue, everyone must be on board. As such, there is no point in me producing something for the Minister which both he and I believe is great and subsequently getting other Departments, elements of government and State actors involved in an action plan if we then return to the joint committee to be told the plan is no good because we would not get buy-in when the legislation starts to come down the tracks. I mean it when I say I want to work with committee. Before I give a firm commitment on this matter, however, I will double-check with the Minister.

We do not know what role legal costs play because this is a matter of dispute. Members will hear this argument because we are already hearing it on our side. We can definitely dig down, find out more information and find out what impact legal costs are having.

Some players in the industry have indicated that legal costs can account for 60% of settlements they make. This speaks to cultural problems we have, about which other commentators have spoken. Deputy John Lahart referred to the journalist Charlie Weston, who has also written about cultural factors. We have considered these types of cultural factors in terms of what precisely is involved in claims and awards and what people expect. FBD Insurance has taken a strong public position on this issue and members will be aware of comments made by its chief executive officer on public expectations with regard to the costs of premiums and awards and managing these two competing or conflicting sets of expectations. A bigger piece of work needs to be done on this issue, which will clearly arise in the public sessions as it has certainly arisen out of the engagements I have had.

Rural-proofing is crucial, and I referred to the difficulties we are experiencing in this regard in my opening comments. As we progress our work, we must examine every type of case study coming through our constituency office doors, whether that of the returning emigrant, the person living in the country, the taxi driver or disabled driver or the driver of a 12 year old car that has passed the national car test and is in great condition. A car built 12 years ago will be in much better condition after 12 years that a car that was built 30 years ago was after 12 years. We must ask, therefore, why a 12 year old car is treated differently when it has been found to be safe in the national car test. We must consider all aspects to ensure we do not miss a trick in finding solutions that will work for everyone. For example, in respect of returning emigrants, I do not see any reason for not accepting official documentation from other jurisdictions. If other countries do this, why can we not do it?

Technology will have a role to play in making the system more efficient. I am aware of one case study related to what is being done in Canada. We will examine this issue in terms of the efficiency with which all of this is done. The industry will point to efficiency factors in terms of costs that contribute to the premiums it sets. It has not provided me with a drilled-down number similar to the figures it has provided on fraud and uninsured drivers. However, this is definitely a component part. Obtaining insurance and tax, passing the NCT and so forth must become much easier and we must ensure all the different technologies are talking to each other.

Deputy Pearse Doherty referred to deadlines in respect of the four sub-committees. I spoke about the composition of the four sub-committees before the Deputy joined us. Each sub-committee has a chair and vice chair. As they progress their role, the subgroups will identify different stakeholders with which to engage. As I indicated to the Chairman, it will be a matter for the sub-committees to invite stakeholders to join the committee. For example, the Central Bank official who chairs one of the sub-committees may pull in any constituent part that needs to be part of the subgroup at any part of the process to take part in the subgroup's work.

We will examine the business model of the insurance sector and insurance companies. This will be part of the work of the first subgroup.

Deputy Pearse Doherty asked about deadlines. I wanted to move with the subgroup model to ensure each aspect of our work received the necessary focus and I was able to interact with each subgroup separately from the plenary working groups to ensure their work was progressing and they were not meeting any unforeseen roadblocks in the process. This is the approach I want to take. In terms of deadlines, therefore, we envisage that the interim report to be submitted to the Minister in October will set out areas on which consensus has been achieved in respect of where the problems lie and what immediate actions need to be taken. As I stated previously, it may be appropriate to return to the joint committee at that point to set out what we are doing in terms of spending the following month or thereabouts trying to secure agreement among the various State and Government actors on specific actions and timelines for starting to implement them.

We need to be cautious about managing expectations. Some things will come on line sooner than others and some may even come on line before the action plan is in place. I hope they will help. From my engagements to date, I believe that if we can show a strong working relationship between the working group I am chairing and the joint committee and achieve consensus on certain actions, we will pre-empt any further serious escalations in premiums. The first subgroup will examine the business model of insurance companies and the issue of transparency, as will the data subgroup, with which it will work closely.

Solvency II has changed provisioning requirements. The data we have been shown indicate that insurance companies have been booking losses.

I will let them explain more about the operating model but we will be looking at that in detail.

I note that members of the committee have been raising this and it has been very much to the forefront of the importance that the Minister, Deputy Noonan, has placed on the different aspects of work. I spoke about this earlier, in terms of setting up the task force. What we have seen in the 12 months to July last is the rocket in insurance premium prices. Increases have been going on for three years. In the first two years, the year-on-year increases for most motorists could be said to be modest, but in the past year, this 38% figure - circa 40% in most cases - has been incredibly significant.

What we have seen also in the past year is motorists finding it almost impossible to get an insurance quote. Deputy Pearse Doherty talked about this aspect. It is also being considered. The sector must come up with a realistic insurance quote. It is not acceptable for it to state that it has offered three quotes when those quotes are completely unaffordable. That does not solve anyone's problems and it appears to be trying to subvert a process that was put in place to protect consumers. That definitely will be looked at.

In terms of the regulation of the sector and the different correspondence Deputy Pearse Doherty has had with the Central Bank, I have met the Central Bank, given its role in this as part of the working group but also its role as regulator of the sector. Nothing has yet been expressed directly to me regarding those concerns that were expressed to the Deputy by the former Governor, Professor Honohan, but we are in constant contact. I will check within the Department as to whether it was copied on any of the correspondence sent to the Deputy from the Central Bank. I will not speak for the Central Bank because it would not be appropriate for me to do so. I assume the committee will meet the Central Bank at some point in its work and the Deputy will have a chance to tease out some of those issues with it in more detail. I do not want to speak for the Central Bank but it can speak as to its responsibilities directly in this area.

There is much better transparency in the United Kingdom and there is no reason we cannot have it here. We are similar common law jurisdictions. Indeed, a number of entities operate in both jurisdictions, on the insurance side but also on the legal side.

I commented on young drivers being refused a quote or given an unfair quote. There is a process whereby a motorist who is refused a quote on three occasions must be quoted for insurance. What we are hearing anecdotally is that motorists are being given unrealistic quotes. It is not that they are being refused a quote; they are given a quote they cannot afford. That is leading to what we are seeing already and what the evidence shows, namely, a dangerous increase in uninsured driving. The increase is large. It is coming from a low base. In terms of the number of overall claims coming in, it is still very low but it is a worrying development. There are, as I said, simple technological improvements that can be made and that are happening in other jurisdictions which can help us address that aspect.

I addressed looking at other models of insurance with Senator Conway-Walsh earlier. We must look at other models of insurance. I have looked at the New Zealand model of insurance. Perhaps I should not be giving a personal view, but I will. That is not the way to go, rather a care-not-cash model is the way to go. That is a personal view and perhaps I should not give it, given my role in chairing this working group. The working group will require big cultural changes in how we go about our business and there will be considerable resistance to some of these changes. Not all of the changes, if they happen, for example, the care-not-cash model, are positive because it might merely end up displacing costs from one sector of the economy to another, for example, from legal to medical. It definitely would help in terms of addressing fraud but this requires further examination. If we can build consensus around this as a route then it will be the way to go but I would not underestimate the difficulty in terms of introducing legislation to make such changes even in that regard, and the kickback that there might be. Nevertheless, if we believe that it is the way to go, we must fight that case.

It will be interesting to hear people's different opinions on those possibilities when it comes to the committee's public sessions. If one looks at the data, one can see the frequency of claims that are related to minor bodily injuries, the award levels for those injuries and how much higher they are then in jurisdictions, what is happening with whiplash and how many more claims there are here than in other jurisdiction, and the evidence that we do not grade whiplash as they do in other jurisdictions. One could have a panel of medical experts in the injuries board process that could be compulsory if one could make it compulsory under the law and that could assess the degree of whiplash according to a graded scale, and then one would not have this fluctuation in terms of the costs awarded.

Once one has such fluctuation and uncertainty, it creates a difficulty for the insurance sector because it must make provision for expected costs under the new requirements and if it does not know, it will always book the higher price.

We are also seeing difficulties around changes in jurisdiction and changes in awards in the courts. To take the prudent course of action, the insurance firm will say it must book the higher price. It would be difficult for us to make an argument against that, if it might be seen to undermine the stability of the sector or the functioning of the market and, of course, the Central Bank would have a say in that as well. However, there are long-overdue improvements and structural reforms that we need to make urgently which, when we get them in train, will make a big difference to how premiums are calculated and the cost of motor insurance for drivers in this country.