Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry – Insurance Hearings

Financial Rights Legal Centre welcomes the opportunity to provide written submissions addressing issues raised during the Insurance hearings of the Commission, noting that this is an area we specialise in, via the work of our Insurance Law Service, in our legal casework and via our policy team. Financial Rights believes it is time for wholesale changes across the insurance industry, with particular regards to:

• An inadequate current regulatory regime, from a consumer protection perspective
• Conflicted remuneration and misaligned incentives
• The sale of multiple unsuitable insurance products, including: consumer credit insurance (CCI), add-on, funeral insurance, accidental death and accidental injury products
• ASIC’s inability to respond to emerging issues and apply Product Intervention Powers to ban some classes of products
• Application of and enforceability of current Codes of practice with regards to all insurers and superannuation trustees
• Ineffective standard/minimum cover regimes
• Inappropriate standard definitions for all key terms and phrases in general and life insurance
• Convoluted and inconsistent Product Disclosure Statements (PDSs) and Key Fact Sheets (KFSs) on insurer websites
• The inappropriate nature of outbound direct sales calls
• Inappropriate pressure sales tactics