Financial Rights strongly support for the work of the NSW Emergency Services Levy Monitor and the development of this discussion paper. The ability for the Monitor to collect and analyse pricing data is vital work to ensure that there is no serious consumer harm arising out of pricing practices and potential exploitation. This paper raises legitimate questions that insurers should answer. The findings that in the NSW general insurance market there may be:
• significant price discrimination leading to an identifiable “loyalty tax”;
• over-insurance borne of possible inappropriate increases to the sum-insured; and
• potentially opportunistic increases in prices of base premiums coinciding with the reduction in the ESL rates
should be of serious concern for NSW consumers.
