The drafting of a Life Insurance Code of Practice follows the industry-commissioned Trowbridge report on retail life insurance advice, which recommended a life insurance code of practice be developed. We are pleased that the FSC has committed to instituting a Code of Practice and believe that this will be of great benefit to both consumers and the industry. Benefits to consumers arising out of the current draft of the Code include commitments moving beyond the law, relating to investigations, surveillance, product suitability, the review of medical definitions and financial hardship. However, we hold significant ongoing concerns with numerous elements of the Code as it stands including time frames, enforceability, group insurance, sales practices and problem products and medical definitions.