Oireachtas Joint and Select Committees

Wednesday, 19 May 2021

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

Developments in the Insurance Industry: Discussion

Mr. Declan O'Rourke:

That is a complicated issue and I know, again anecdotally, that the UK is struggling with it. The objective of it is good and, certainly, protecting vulnerable customers is very important. Aviva has led the way on this, even as far back as 2019 when we put a cap on the difference between new business and renewal business, which for a direct channel in Ireland is 25%. That is an important one. Nobody wants to see a situation where people are being charged large premiums, especially vulnerable people, as it is not right. We have acted on that. We have led the market and both regulators have seen that.

That is an important piece but there are other unintended consequences of this. There is no doubt the people who shop around now get a good deal and they will not get as good a deal afterwards if dual pricing is banned because, at the moment, incentives for new customers to try to encourage customers on board are probably being compensated for by older customers. That is the way a lot of markets work, including this market.

There is a lot to it. I know the FCA is grappling with what is going to happen with back books, where there is no new business and where less than 15% of the business is new business. I know it is grappling with margin versus price and with discounts on new business. It is having its own tangled web with this. We need to be careful we do not end up in a situation where, like the health industry, the products are 99% the same but the prices are different and we end up with an awful lot of products. We would fear that certain players might be able to get involved in sharp practice because there would be quite an opportunity within a very strong regulated market like that.

We all want to protect vulnerable customers. We monitor our pricing for vulnerable customers versus our overall book to make sure there are no significant differences. I agree we need to protect vulnerable customers but we need to be careful with the market as well because some unintended consequences could happen.