On 20 June 2017, the Financial Conduct Authority (“FCA“) published a Call for Input inviting firms (amongst other stakeholders) to submit their views on the challenges they face in providing travel insurance to consumers who have (or have had) cancer (“Relevant Consumers“) by 15 September 2017.
In May 2016 the FCA published its Occasional Paper on Access to Financial Services. This paper provided a high-level overview of the major trends across a range of financial services and identified some key issues that can make it difficult for some consumers to access them.
The FCA has made it a priority to address these issues in its 2017-2018 business plan. See here for further information.
One of the main problems is that some consumers who may previously have had good access to insurance products can become marginalised. A good example of this is where a consumer has suffered or is suffering from an illness and consequently finds it more difficult to find a travel insurer willing to cover them.
What does the call for input ask for?
The FCA is seeking views, examples and evidence of the challenges firms face when providing travel insurance to Relevant Consumers, and the reasoning for pricing differentiations in quoted premiums.
In summary, the FCA has requested input in relation to the following areas:
- challenges for insurers in providing travel insurance for Relevant Consumers;
- challenges for Relevant Consumers in accessing the market and finding suitable travel insurance;
- examples of innovative practices;
- barriers to addressing existing challenges and to innovation; and
- suggestions for what more can be done to improve the ability of Relevant Customers to obtain suitable travel insurance.
Further details are set out in the Call for Input and a comprehensive list of questions is included at Annex 1.
The deadline for responses is 15 September 2017.
The FCA has further plans to improve its understanding of the issues facing vulnerable customers when accessing financial markets. It intends to publish a feedback statement later in 2017 in which it will set out its next steps to achieve this. We will provide an update on this blog when that statement is released.
If you would like to discuss any issues arising from the FCA’s Call for Input, please contact a member of the Hogan Lovells team.