10
CP19/23
Chapter 3
Financial Conduct Authority
Signposting to travel insurance for consumers with medical conditions
3.6 If a consumer has been declined cover, or received a quote with a PEMC exclusion,
further shopping around is clearly likely to be beneficial. But if they have a quote
including cover for their condition, further shopping around will not always help. For
some, shopping around could result in a significant reduction in premium, while for
others, the initial provider may offer the best rates.
3.7 It is difficult to identify a trigger point for disclosing the directory information that
is both proportionate for firms to implement and which maximises getting the
information to those consumers most likely benefit, reducing consumer harm to the
greatest extent. We are proposing that all consumers with an additional loading to their
premium are notified of the directory. We considered the following options, some of
which were suggested by our stakeholders, for triggering the notification:
a. A medical screening score threshold, above which the notication is triggered.
This provides an objective test to trigger the disclosure. Also, the severity of a
new entrants to the market.
b. A premium amount threshold, above which the notication is triggered.
(a) in deciding on an appropriate threshold. Some stakeholders suggested that
signposting could be triggered at the price point above which only a very small
of consumers, then they should consider if they are meeting their wider regulatory
c. All consumers who declare a PEMC are notied. This also provides an objective
test, but would capture a large number of consumers who have no loading to their
premium (approximately 12% of those medically screened go on to receive no
additional loading, and a further 27% get a very low screening score and so could be
d. All consumers who receive an additional loading to their base premium, due to
a PEMC, are notied.
implement. It should also ensure that the disclosure is made to those consumers
shopping around further. But, on balance, we believe that this is the best option.
3.8 We want to limit the risk that consumers with a minimal loading (often due to a very
we propose that when signposting the consumer to the directory, firms indicate which
consumers are more likely to benefit from using it and state the potential benefits
of accessing it. They can explain it is likely to be more helpful for consumers with
condition.