Annuity Risk India https://annuityrisk.in Life Insurance and Annuity Risk Management Mon, 14 Oct 2024 06:26:10 +0000 en-US hourly 1 https://wordpress.org/?v=6.2.6 https://annuityrisk.in/wp-content/uploads/2023/06/cropped-AR_Favicon-32x32.png Annuity Risk India https://annuityrisk.in 32 32 IRDAI’s New Directive: No Premium Collection Before Policy Acceptance https://annuityrisk.in/2024/09/13/irdais-new-directive-no-premium-collection-before-policy-acceptance/ Fri, 13 Sep 2024 13:48:42 +0000 https://annuityrisk.in/?p=10761 Annuity Risk India - Life Insurance and Annuity Risk Management

Exploring IRDAI’s New Regulations and Their Impact on the Insurance Industry The Insurance Regulatory and Development Authority of India (IRDAI) issued a Master Circular on the Protection of Policyholders’ Interests on September 5, 2024. A key provision in this circular is that insurers can only request the payment of the premium or premium deposit after...

Annuity Risk India - Life Insurance and Annuity Risk Management
IRDAI’s New Directive: No Premium Collection Before Policy Acceptance

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Annuity Risk India - Life Insurance and Annuity Risk Management

Exploring IRDAI’s New Regulations and Their Impact on the Insurance Industry

The Insurance Regulatory and Development Authority of India (IRDAI) issued a Master Circular on the Protection of Policyholders’ Interests on September 5, 2024. A key provision in this circular is that insurers can only request the payment of the premium or premium deposit after they have accepted the proposal. The circular mandates that insurers must process proposals swiftly and efficiently, with a strict deadline of 7 days from the submission of the proposal.

Earlier this year, IRDAI had published the Insurance Regulatory and Development Authority of India (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024 in the official Gazette of the Government of India which extended the Free Look period to 30 days. 

This article will explore the past regulations compared to the new ones to highlight the changes and discuss their implications for the insurance industry in India.

Superseded Regulations

The Insurance Regulatory and Development Authority of India (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024, published on March 20, 2024, supersede the following regulations:

  1. The Insurance Regulatory and Development Authority (Manner of Receipt of Premium) Regulations, 2002
  2. The Insurance Regulatory and Development Authority of India (Places of Business) Regulations, 2015
  3. The Insurance Regulatory and Development Authority of India (Fee for Registering Cancellation or Change of Nomination) Regulations, 2015
  4. The Insurance Regulatory and Development Authority of India (Fee for Granting Written Acknowledgment of Receipt of Notice of Assignment or Transfer) Regulations, 2015
  5. The Insurance Regulatory and Development Authority of India (Issuance of eInsurance Policies) Regulations, 2016
  6. Insurance Regulatory and Development Authority of India (Outsourcing of Activities by Indian Insurers) Regulations, 2017
  7. The Insurance Regulatory and Development Authority of India (Protection of Policyholders’ Interests) Regulations, 2017
  8. The Insurance Regulatory and Development Authority of India (Insurance Advertisements and Disclosure) Regulations, 2021

Changes to the Free Look Period

In 2017, IRDAI regulations provided a Free Look period of 15 days for policyholders to review the terms and conditions of their policy, or 30 days in the case of electronic policies or those obtained through distance modes. Policyholders could request the cancellation of the policy within this period and were entitled to a refund of the premium, subject to deductions for a proportionate risk premium, medical examination expenses, and stamp duty charges. Refunds had to be processed within 15 days.

Under the new regulations of March 20, 2024, every policyholder of life insurance and new individual health insurance policies, except for those with tenures of less than one year, is entitled to a Free Look period of 30 days, regardless of whether the policy document was received electronically or in physical form. Requests for cancellation during the Free Look period must now be processed, and the premium refunded, within 7 days.

While a longer Free Look period benefits consumers by giving them more time to review their policies, it could also lead to increased competition among insurers. Consumers may use this period to seek quotations from multiple companies, potentially leading to aggressive sales tactics from insurers attempting to persuade policyholders to switch policies. However, this extension may reduce hesitation among consumers when purchasing policies, benefiting the industry as a whole.

Premium Payment and Risk Commencement

According to the Insurance Regulatory and Development Authority (Manner of Receipt of Premium) Regulations, 2002, an insurer’s liability begins only after receiving the premium. While the IRDAI did not explicitly mandate that the first premium must be paid along with the proposal form, this became a common industry practice to initiate the underwriting process. In the event that something happens to the proposer before the process is completed, the policy is not yet active, and the customer or their beneficiary is entitled only to a refund of the first premium paid. No sum assured is payable.

However, Under the Master Circular on Protection of Policyholders’ Interests, 2024 (published on September 5, 2024), premium payments are now required only after the insurer has communicated acceptance of the proposal. The risk cover begins only after the premium is received, except in the case of policies issued based on a declaration of good health, where the risk commences immediately upon premium payment. Insurers must ensure that explicit consent is obtained from the policyholder for any premium deductions, and no premium deposit or proposal deposit is required alongside the proposal form. Additionally, insurers must provide prospects the option to choose between electronic and physical policy documents.

Old Regulation New Regulation
Free Look Period

15 days for policyholders to review their policy, or 30 days for electronic policies.

30 days, regardless of whether the policy document was received electronically or in physical form.

Refund Processing Time (Cancellation During Free Look Period)

15 days

7 days

Premium Payment

First premium payment along with the proposal

Premium payments required only after the insurer has communicated acceptance of the proposal.

Underwriting process

30 days to process and the decision is communicated within 15 days.

insurers must process proposals within 7 days and communicate them within this 7-day timeframe.

Proposal Processing and Policy Issuance

Previously, insurers were required to process proposals free of charge within 30 days. They were also mandated to communicate their decision to the proposer within 15 days of receiving the proposal or any additional requirements.

Now, under the 2024 regulations, insurers must process proposals within 7 days. If additional details or clarifications are required, insurers must request them in a single instance, not on a piecemeal basis. The proposal decision must be taken within the 7-day window.

Insurers are required to furnish the following documents to the prospect within 15 days of accepting the proposal:

  1. Policy document
  2. Copy of the proposal form submitted by the prospect
  3. Customer Information Sheet
  4. Medical Reports, if applicable

For online sales, a customer pre-paying the initial premium would previously validate the policy and reduce underwriting risks for the insurer. However, under the new regulations, insurers must complete the due diligence and underwriting at their own cost, which could include medical tests (often involving home visits, blood tests, and ECGs) that cost approximately ₹1000 per person. While eKYC via Aadhaar costs less than ₹1 per person, the administrative burden of preparing policy proposals and documentation of test reports will be a significant challenge for insurance companies.

Annuity Risk India - Life Insurance and Annuity Risk Management
IRDAI’s New Directive: No Premium Collection Before Policy Acceptance

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Hello 2024! https://annuityrisk.in/2023/12/30/life-insurance-2024-outlook/ Sat, 30 Dec 2023 12:36:52 +0000 https://annuityrisk.in/2023/12/30/interdum-luctus-accu-samus-habitant-error-nostra-nostrum-copy/ Annuity Risk India - Life Insurance and Annuity Risk Management

Here are the 7 big changes to watch out for in 2024. 1. Higher Guaranteed Surrender Value   Certainly, higher guaranteed surrender values of life insurance policies are superbly positive for the policyholder. We don’t label it as some sort of a victory of the consumer over the insurer, because in the long run, they...

Annuity Risk India - Life Insurance and Annuity Risk Management
Hello 2024!

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Annuity Risk India - Life Insurance and Annuity Risk Management

Here are the 7 big changes to watch out for in 2024.

1. Higher Guaranteed Surrender Value

 

Certainly, higher guaranteed surrender values of life insurance policies are superbly positive for the policyholder. We don’t label it as some sort of a victory of the consumer over the insurer, because in the long run, they both are on the same side. We see this as a win for the entire market. For example, the automobile industry has been keeping up with increasingly higher quality standards that were demanded by the regulator and not by the consumer. And yet the automobile market has been growing (despite steepest taxes!), and automakers are thriving! Higher standards of product quality in the automobile market, albeit enforced by regulation, have only increased safety, and led to increased product adoption and expanded the overall market of automobiles.

Life insurance is typically the first ever financial product to be purchased by an individual on her path to financial security. A better first experience for her will pave the way for higher satisfaction, repeat purchases and better word of mouth recommendation in future (which drives sales like nothing else!).

Nevertheless, we are eager to observe how IRDAI wrestles with the comments and feedback it receives on the draft. Because, let’s agree, it is trying to do something that should have been done by competitive forces already by now. We think IRDAI will need some solid muscle in pushing down the threshold value for the new calculation of guaranteed surrender value.

2. Index Linked Insurance Products (ILIP)

Index-linked insurance products will be exciting, although not new to the Indian consumers. Index linked products have been phenomenally successful in the US life insurance and retirement market. Linking the account value to a market-cap-weighted index can lower the manufacturing cost of policies since those pesky mutual fund ‘management’ fees will go away. Insurers may need to pay for a small licensing fee for the index, but it will be a fraction of what mutual funds charge to ULIPs. Moreover, ILIPs will make it easier for retirees to allocate a portion of their savings to equity, leading unarguably to higher growth in account values and more prosperous retirements.

3. Commissions Going Down

More online aggregators, more competition, lower commissions, and hence more money for the policyholder.

4. Election ‘Semester’

We are calling it a semester of goodies because, let’s agree, it will be over by June. India’s public debt is rising fast, but tax to GDP ratio is not rising commensurately. Oh, by the way, we are assuming (our base case scenario) that the government will remain in power. And even though the government may not immediately shift towards a higher tax (or lower subsidy) regime, markets will certainly want to price it right away.

5. Risk of Weakness in Credit Markets

Credit spreads, which show the difference between a corporate bond yield and government bond yield of corresponding maturity, have been the lowest ever that India debt market has seen. And, while the yield curve is still upward-sloping, any shocks to credit or inflation will create mark-to-market losses and reduce the investment earnings of insurers. Inflation is already running above target and it does not seem that RBI will be in a position to cut rates even if the Federal Reserve does cut rates by mid-2024.

6. Higher Regulatory Burden

IFRS 17 and Risk-Based Capital are two separate and major accounting overhauls that are coming soon. We reckon that both steps are in the right direction. To put it politely, the life insurance industry has a flair for making sure that no accountant or auditor is ever out of a job. But then, we the people, also wonder whether is it not the poor retiree who is paying for it all. 

Most actuaries will agree that the reporting burden on India insurers is already high by international standards. Moreover, this increasing regulatory and reporting burden makes it even harder for new entrants and smaller insurers to do business.

7. Technology Acceleration

Thanks to the internet and advancements in communication technology further accelerated by AI, consumers are more informed than ever. We see that most prospective policyholders have already done some market research before initiating dialog with their retirement advisor. This shift in consumer behavior will undoubtedly force life insurers to make significant efforts towards enhancing the quality of their products and offering higher value for money. 

On behalf of the entire Annuity Risk team, we wish everyone a very happy and successful new year ahead.  

Annuity Risk India - Life Insurance and Annuity Risk Management
Hello 2024!

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Inclusion of Indian bonds in JP Morgan GBI-EM Index https://annuityrisk.in/2023/10/11/indian-debt-jpm-index/ Tue, 10 Oct 2023 23:45:43 +0000 https://droitthemes.com/wp/makro/2020/04/19/test-copy-copy-3/ Annuity Risk India - Life Insurance and Annuity Risk Management

What about the inclusion of Indian Government Bonds in JPMorgan’s Government Bond – Emerging Market Index (GBI-EM)? In the last few weeks, we have received many queries about the inclusion of Indian Government bonds in JPMorgan’s Government Bond Index (GBI-EM). Here we present a few of those questions and answers. Will this change lead to...

Annuity Risk India - Life Insurance and Annuity Risk Management
Inclusion of Indian bonds in JP Morgan GBI-EM Index

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Annuity Risk India - Life Insurance and Annuity Risk Management

What about the inclusion of Indian Government Bonds in JPMorgan’s Government Bond – Emerging Market Index (GBI-EM)?

In the last few weeks, we have received many queries about the inclusion of Indian Government bonds in JPMorgan’s Government Bond Index (GBI-EM). Here we present a few of those questions and answers. 

Will this change lead to an increase in the liquidity of Indian Government Bonds?

No

GBI-EM Index follows a ‘buy-and-hold’ type of strategy. GBI-EM index does not have a particular duration target. So, bonds once purchased remain on the balance sheet of the asset manager for a very long time, or until 13 months are left before maturity. 

The best analogy we can find is when the Federal Reserve Bank of United States purchased bonds of specific maturity during the ‘Operation Twist‘ of Quantitative Easing. In this operation, Fed’ purchase of certain long dated bonds did not increase the liquidity of those bonds. Fed actually informed the market which bonds it will buy, and when, which lead to a momentary uptick in the price of those bonds (as expected). 

 We expect that the liquidity of Indian bonds purchase (or purchased) will actually decrease since the funds are going to be following the buy-and-hold strategy of GBI-EM Index.


 

Should we expect a significant uptick in price of Indian Bonds eligible for inclusion within the GBI-EM index?

No

Limiting our attention to ISINs listed under Fully Accessible Route, we see USD 420 Billion of outstanding Indian Sovereign debt, out of which approximately USD 330 Billion have a remaining duration of 5 years or more. Assuming a monthly purchase of USD 2.5 Billion out of this USD 330 Billion (and growing) pool of debt, the uptick would be transient, if at all. We expect USD asset managers to partner with local fund managers and primary dealers in India to acquire these bonds in size. And, as a result, we expect that there will be negligible frictions available to exploit.

FPIs are permitted to invest in all dated Government Securities with more than 3 years to maturity (but still limited to USD 25 Billion per FPI, which is a really high limit!).


 

Will this change bring in huge amounts of USD inflows and hence cause the Indian Rupee to appreciate against the US Dollar? 

No. 

The expected USD inflows due to this index alone are going to be in the range of USD $2-3 Billion a month. Compare that to the change in FPI Net Investments from +$36B in 2020-21 to  -$16 B in 2021-22. Such a wide range makes a net inflow of $23 B difficult to interpret, especially given FPIs are a minor driver of net FX flows in comparison to trade  (import/export). An important fact to understand is that GBI-EM is a local currency index, which means foreign asset managers hold EM bonds in their native currencies and do not hedge their FX exposure. So, this means that this index will make dollars flow into India, but the scale is not large enough to have any material effects on FX rates.


 

Interest rates in the emerging markets have been much higher than in the US. So, this index must be a good investment, providing high yields (high returns) to US investors. 

No.

Although it is true that sovereign bond yields are much higher in the developing world (Brazil 11.5%, South Africa 10.5%, Mexico 10%, Turkey 25%, etc.), US Dollar’s relentless rise against these currencies makes the total returns look poor when they are converted back into USD. The 10 year return on GBI-EM Index for a typical US-based investor is -1.5%, and 5 year return is -0.5%. After adding an expense ratio of -0.3% per year, the total long-term return on this index looks very bad to a US-based investor.


 

Are there other indices like GBI-EM, which may include Indian Government Bonds soon?

No.

Wisdom Tree’s Emerging Market Local Debt Fund (ELD ETF) is another fund that holds Emerging Market debt in respective local currencies. Surprisingly it even holds the debt of Russia (12% yield), Peru (7.5% yield) and Turkey (25% yield), all of which tend to have enormous FX volatility. But this fund does not hold Indian Sovereign debt. SPDR’s EBND ETF, which tracks the Bloomberg  EM Local Currency Government Diversified Index is another such local currency debt fund. EBND holds the sovereign debt of Romania, Peru, Chile, Turkey, and even Colombia, but not India. Hence, we think that ELD and EBND will not include Indian Sovereign Debt in the future. Even if they do, the AUM of these funds (and other funds related to their indices) is quite low making them insignificant.


 

Surely, the inclusion of Indian Government Bonds in a large and reputed index like JPM’s GBI-EM Index will increase the creditworthiness of Indian Government Bonds in the global debt market. 

No.

Despite inclusion in major Local Currency Debt indices, many emerging countries have seen their yields going up and currencies going down (relative to USD) in the last 5 years. Both trends indicate worsening creditworthiness. The creditworthiness of a country is determined by its ability to collect taxes, in addition to other domestic market factors such as inflation, economic growth, and stability in political, regulatory and business environments. It is important to understand that the investor of Local Currency Debt is taking exposure to both local interest rates and FX risk. A US-based investor will suffer a loss when the EM debt yields rise or when the EM currency depreciates against the dollar. And, evidently, a US-based investor has suffered huge losses on both fronts (local interest rate risk and fx risk) in the last 10 years on the debt of many emerging market countries.


 

I understand it now. Investing into Indian local currency bonds must have been a loss-making investment for US-based investors, and so they do not like to include Indian bonds in their indices. 

No. 

An investment made into INR Government Bonds 10 years ago would have yielded an annualized return of 5% in USD terms. Likewise, an investment made into Indian Government Bonds 5 years ago would have produced an annualized return of 4.8%. So, historically, local currency investments into Indian Government Bonds have largely remained quite profitable for a US-based investor, after including for both interest rate risk and fx risk. 


 

So, is it true, then, that these other indices (besides JPM’s GBI-EM) continue to include sovereign debts from many emerging countries despite persistent losses and worse future outlook, but continue to exclude and ignore Indian sovereign debt despite positive historical returns and positive future outlook? 

Yes. 

That seems to be the unfortunate reality. Despite capital controls, foreign institutional investors (FIIs) have enjoyed very liberal caps on investment in rupee-denominated sovereign debt (USD 25 Billion) since 2013. In October 2019, FIIs (renamed as Foreign Portfolio Investors) were given explicit approval to invest in various kinds of government and commercial debt in India via the Foreign Exchange Management (Debt Instruments) Regulations (Notification).

Foreign ownership of Indian Sovereign debt still remains under 2% of all outstanding debt. Compare that to the foreign ownership of sovereign debt of Indonesia (~ 25%) or that of South Africa (~ 35%).  


Annuity Risk India - Life Insurance and Annuity Risk Management
Inclusion of Indian bonds in JP Morgan GBI-EM Index

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Unrewarded Risks: Part 1 https://annuityrisk.in/2023/07/29/unrewarded-risks/ Sat, 29 Jul 2023 04:58:40 +0000 https://droitthemes.com/wp/makro/2020/07/12/we-craft-marketing-digital-products-that-grow-businesses-copy/ Annuity Risk India - Life Insurance and Annuity Risk Management

  Policyholders care most about the guarantees they received and the price they paid for those guarantees. In other words, they want the best quality insurance policies at the lowest prices, which is no secret at all. What they don’t care about is how insurers built them.  Developing software technology in-house has always been a...

Annuity Risk India - Life Insurance and Annuity Risk Management
Unrewarded Risks: Part 1

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Annuity Risk India - Life Insurance and Annuity Risk Management

 

Policyholders care most about the guarantees they received and the price they paid for those guarantees. In other words, they want the best quality insurance policies at the lowest prices, which is no secret at all. What they don’t care about is how insurers built them. 

Developing software technology in-house has always been a key operational risk at insurance companies. The ever-increasing complexity of today’s life insurance and annuity products increases this risk manifold. And, all this risk is not rewarded by policyholders – they just don’t care. 

 

Software technology for life insurance and annuity data requires cross-disciplinary expertise in software development and delivery, high-performance computing, databases, data security, actuarial and quantitative finance, and advanced data analyses. Life insurance companies could instead focus on their core expertise, instead of chasing people with skills in technology development. One may argue that the core competency of life insurance companies lies in designing, manufacturing, and selling top-quality insurance policies, and then thrilling their customers with exceptional customer service – because that is what their customers care most about.

 

Policyholders reward the best quality insurance policies available at the lowest prices. Policyholders don’t care about the risks that insurers took to build those policies.

Outsourcing software technology development can offer many advantages to an insurer. 

  1. Gaining valuable time: Building internal teams can be a huge drain on management’s time. Hiring, training, and establishing an effective culture can divert management’s focus away from the competition. 
  2. Cost savings: Hiring well-trained people is expensive, to begin with, and retaining them gets more expensive when all the competitors are clustered within a 10-mile radius. Moreover, insurers often find themselves hiring multiple employees for the same task in order to ensure business continuity. The high costs of living in major metropolitan areas such as Mumbai and Gurgaon add to this cost. Once the project is completed, the insurer typically won’t let those extra employees go, and instead will try to ‘absorb’ them into other functions and capacities, unnecessarily swelling its payroll.
  3. Higher utility: The solution from a third-party service provider will typically have a higher quality (utility) than that of a solution built internally, simply because the service provider has seen more variations of the same problem and has crafted a solution to deal with all those variations. In other words, the third-party solution will be able to solve problems and handle situations that the insurer has not seen yet in its own operations. 
  4. Implementation (Execution) Risk: The biggest unrewarded risk lies in execution. Taking a project from ideation to delivery is enormously challenging within large corporations, and expert project managers can tell you all about it. Many team members and leaders will quit during the project, causing a waste of time and resources, or cancellation of the project altogether. Again, policyholders don’t care about the sacrifices made by management, and won’t reward them.
  5. Focus on strategic goals: Senior management should be able to stay focused on their strategic goals, which include mastering competitive forces, understanding customer feedback, preparing for upcoming regulatory changes, and maximizing returns to shareholders. The task of setting up and running large data and software teams disrupts management’s focus and drains management’s time.

 

Engaging third parties such as Annuity Risk in non-core capabilities such as software technology and data management can allow insurers to realize the full potential of their products, reach new heights of customer service and product quality, and gain market share.

Annuity Risk India - Life Insurance and Annuity Risk Management
Unrewarded Risks: Part 1

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