The Rag Letters
As phase 3 of the red, amber, and green endowment re-projection letters go out to indicate the extent of any potential short- fall in the maturity value of mortgage endowment policies, the life insurance industry is facing a significant challenge: Quite apart from the matter of compensating those policyholders for whom it has been proven that their policies had been mis-sold, the industry needs to know how many complaints it can expect and of vital importance when they are likely to materialise.
The problem of predicting complaint rates is far from easy to solve and the implications of getting it wrong are rising complaint backlogs and attendant FSA scrutiny. Looking at some of the numbers involved gives an idea of the scale of the problem. The most recent data, albeit dating back to , shows that there were then some 11m policies to be reviewed.
This may well have decreased to under 10m since then as a result of surrenders boosted by surrenders due to upheld complaints , but by any measure the problem is enormous. Take a look at history What can we learn from history? Phase 1 of the three-phase endowment complaint process saw complaint rates of around 1.
Accurate prediction of complaint rates for phase 3, which is just starting, is therefore vital for an assessment of the compensation and reserving requirements. In order to achieve an accurate prediction of complaint rates, the industry must take a number of additional factors into account, not least, the timing of the dispatch of re-projection letters and press activity. Given the impact that size of shortfall has on complaint rates, this guidance will have a huge influence on complaint rates but it is by definition specific to each life company there is no one-size-fits-all solution.
How long is the tail? An equally important challenge for the industry is to determine the timing of likely complaints.
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