1

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EVENTS30

PO Box R1832, Royal Exchange, Sydney NSW 1225

t 02 9253 5100 f 02 9253 5111

www.insurancecouncil.com.auwww.understandinsurance.com.au

CEO’S MESSAGE 4

BOARD OF DIRECTORS 6

EXECUTIVE TEAM 8

ADVANCING SELF-REGULATION 9

COMMITTED TO CONSUMERS 10

CONTRIBUTING TO REFORM PROPOSALS 14

RESILIENCE POLICIES PROTECTVULNERABLE COMMUNITIES 15

THE ANGRY SUMMER 18

SIGNIFICANT GAINS WITH ONGOING CHALLENGES 23

EXTERNAL FORCES 25

FSL AXED BUT TAX REFORM AGENDA REMAINS 27

2013 EVENTS 30

SUBMISSIONS 34

COMMITTEES AND WORKING GROUPS 37

ICA MEMBERS AND BRANDS 38

CONTENTS

EXTERNAL FORCES25

CEO’S MESSAGE4

THE ANGRY SUMMER18

COMMITTED TO CONSUMERS10

THEYEAR INREVIEW

Cover: A lone waratah stands in front of a cafe threatened by a bushfire at Bell in the Blue Mountains (AAP)

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CEO’SMESSAGE

This year, the Insurance Council of Australia (ICA) directed much of its energy towards reinforcing the value of insurance to the public, governments and other stakeholders through action, education and innovative programs.

Though most insurance claims do not involve natural disasters, it’s when catastrophes hit that insurance attracts the most attention, and creates the opportunity for this sector to demonstrate its bona fides.

This year the industry worked from a well-rehearsed process and responded to the catastrophes rapidly, efficiently and effectively. Call centre staff were ready. Assessors were among the first non-emergency services people to enter catastrophe-hit regions. In general, claims were managed very quickly and customers received what they were promised in their contracts.

There is no doubt in my mind that insurers have become incredibly adept at responding to these events. They provide the resources and processes required to help their customers through incredibly stressful times, and prove insurance delivers on its promise.

In many ways these catastrophes, in particular the horrors of the Tasmanian and Blue Mountains bushfires and the inundation of the Wide Bay-Bundaberg region, served another purpose. They helped to pinpoint the urgent need to protect at-risk communities, highlight the concerning rate of underinsurance in the community and renew the focus on measures that could reduce pricing pressures.

Australia’s legacy of building communities in areas exposed to extreme weather must now be handled more prudently, with greater attention paid to appropriate land-use planning. The industry is encouraged by the Productivity Commission report into climate change adaptation, which recognises the importance of the price signal that insurance sends about the need to adapt and reduce risk. However, these signals are only useful if they are observed, understood and generate action.

The ICA continues to work closely with governments and consumers to help communities understand risks and work towards practical solutions. It has initiated programs to tackle the impacts of extreme weather and improve the availability of hazard data to help understand risk and develop a more sustainable response to managing catastrophes.

The insurance industry is vital to Australia’s economy and the sustainability of its communities, yet its importance to our way of life is all too easily overlooked.

Robert WhelanExecutive Director and CEOInsurance Council of Australia

But industry can’t do all the heavy lifting. Governments must work to identify the worst of the exposures that the community is forced to live with, and take action to remove or reduce hazards to acceptable levels. I am greatly encouraged by the Queensland Government’s efforts to build mitigation infrastructure and provide data through a Memorandum of Understanding with the ICA.

Removing taxes and levies on insurance can help reduce underinsurance and non-insurance. More insured properties means fewer demands in the future on governments and community organisations following disasters.

Tax reform therefore remains high on our agenda. On July 1, the industry welcomed the removal of the Fire Services Levy from Victorian insurance premiums. This is great news for policyholders, who have generally experienced a sharp drop in the price they pay for policies. The ICA remains hopeful the New South Wales Government will renew its own emergency services levy reform process next year.

The industry continues to evolve in the way it interacts with all levels of the community. This year the ICA completed an independent review of the General Insurance Code of Practice. The Code has new provisions and governance structures and an emphasis on the importance of appropriate customer service levels. It will be launched in mid-2014.

The ICA has also made real progress in enhancing its consumer engagement agenda with initiatives that strengthen its capability to support consumers. The most notable of these is the new Understand Insurance financial literacy program, and the expansion of the Find an Insurer service. These programs do much to help consumers understand how insurance works for them and how to go about finding the most suitable insurance product for their needs.

For all these achievements, the insurance industry still face formidable challenges, in particular ensuring insurance is accessible and affordable to the community. I am confident the industry is up to this and many other challenges.

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BOARD OFDIRECTORS

Mr Ian BergVice President and Operations Manager

Australia, FM Insurance Company LimitedNon-Executive Director since 2009

Mr Heinrich EderManaging Director, Munich Holdings of

Australasia Pty LimitedNon-Executive Director since 2005

Mr Richard EnthovenManaging Director

The Hollard Insurance Company Pty LimitedAppointed on May 2, 2013

Mr Niran PeirisManaging Director

Allianz Australia Insurance LimitedAppointed on January 9, 2013

Mr Rob WhelanExecutive Director and Chief Executive Officer

Insurance Council of Australia Limited Executive Director since 2010

Mr Andy CornishChief Executive Officer

Direct InsuranceInsurance Australia Group Limited

Non-Executive Director since 2012

Mr Colin FagenChief Executive Officer

QBE Insurance (Australia) LimitedNon-Executive Director since 2011

Mr Adrian HumphreysAustralian Country Manager

Lloyd’s Australia LimitedNon-Executive Director since 2012

Mr Mark MillinerChief Executive Officer

Personal Insurance Suncorp Group Limited

Non-Executive Director since 2009

Mr Noel CondonChief Executive OfficerAIG Australia Limited

Non-Executive Director since 2011

Mr Daniel FogartyChief Executive Officer

Zurich Financial Services Australia Limited

Appointed on January 9, 2013

Mr Mark SenkevicsManaging Director and Head of Australia and

NZ, Swiss Reinsurance Company LimitedNon-Executive Director since 2012

PRESIDENT

DIRECTOR APPOINTMENTS DURING 2013

DIRECTORS

Mr Robert ScottManaging DirectorWesfarmers General Insurance LimitedNon-Executive Director since 2009, President 2011-12

DIRECTOR RESIGNATION DURING 2013

DEPUTY PRESIDENT

EXECUTIVE DIRECTOR

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EXECUTIVETEAM

Rob WhelanExecutive Director and CEO, Insurance Council AustraliaJoined on March 22, 2010

Campbell FullerGeneral Manager Communications

and Media RelationsJoined on October 24, 2011

Karl SullivanGeneral Manager

Policy Risk and Disaster

Joined on September 4, 2006

Brian FrancisCompany Secretary and

General Manager Corporate Services

Joined on May 26, 1997

Richard ShieldsGeneral Manager Government and

Stakeholder RelationsJoined on June 17, 2013

John AnningGeneral Manager Policy

Regulation

Joined on April 2, 2007

Alex SanchezGeneral Manager Policy Economics and Taxation

Joined on September 5, 2006

Vicki MullenGeneral Manager Consumer

Relations and Market Development

Joined on January 16, 2012

ADVANCING SELF-REGULATIONAfter a 12-month review of the General Insurance Code of Practice, independent reviewer Ian Enright presented his 200-page report to the Insurance Council of Australia’s Board in May.

The report drew from various recommendations from recent state and federal government inquiries and from a diverse range of submissions and opinions from consumer groups, government, regulators and industry.

The Code was first developed and introduced by the ICA in 1994, reviewed in 2006 and 2009, and last revised in 2012. Mr Enright’s independent report was the most comprehensive review ever conducted.

In the second half of 2013, the ICA’s Working Group worked on the draft revised Code. Consultations were organised with consumer advocates, the Financial Ombudsman Service and the Australian Securities and Investments Commission, with a formal consultation period held in November. Key issues canvassed during this period were Code provisions for financial hardship, claims handling and the internal complaints process.

An overarching theme of the report was the importance of Code governance, and the ICA and its member companies agreed an enhanced and more independent governance body was an appropriate vehicle for compliance monitoring and sanctions.

The separation of powers is a fundamental tenet of any well-functioning governance model, and the ICA believes the general insurance industry’s framework for self-regulation of service standards is no different.

Taking into account Mr Enright’s comments on improving governance, the ICA sees value in separating the roles of monitoring and enforcing Code compliance from the ICA’s role of developing the content of the Code and attendant policies.

ICA members believe it is important for the ICA to retain the responsibility for developing industry policy, including Code content. The ICA has the experience, relationships

and resources to enable it to consult widely with its members and external stakeholders, and to determine the appropriate framework for industry self-regulation under the Code.

The ICA and its members will continue to take responsibility for financial literacy programs and staff education and training. The ICA has already put in place significant projects to address consumer needs, including forming a Financial Inclusion Committee of industry representatives, developing the Understand Insurance campaign (launched in November), and operating a consumer referral service (which the ICA took over from the Financial Ombudsman Service in July last year).

Next year, the ICA Board will consider significant revisions to the Code that will take into account the recommendations of the independent review, with a revised Code to be introduced in July 2014.

Right: Ian Enright discusses industry self-regulation at the 2013 Regulatory Update

11 Left: ICA CEO Rob Whelan speaks at the launch of Understand InsuranceAbove: Understand Insurance is designed for use on desktop computers and mobile devices

The Insurance Council ramped up its direct engagement with consumers through several initiatives that help improve public understanding of the value of insurance.

After a year in development, Understand Insurance – the ICA’s groundbreaking consumer financial literacy initiative – was launched in late November.

Understand Insurance empowers consumers and businesses to make well-informed decisions about their insurance needs and take control of their purchasing decisions.

Understand Insurance was developed with the supportof the ICA Board and flowed from the concerns of consumers, policyholders, governments and consumer advocates following the catastrophe-packed years of 2010-2011.

The program bridges information gaps and opens up the lines of communication with consumers, business owners and Australian communities.

The main focus of the new literacy program is a consumer-friendly and information-rich website, www.understandinsurance.com.au.

The website demystifies insurance, guiding Australians in simple, easy-to-understand terms through the insurance

process, from understanding their insurance needs through to making a claim. It is packed with details on the types of products, consumer testimonials, downloadable checklists and guides.

This information is also proving handy for insurance brokers, advisers, consumer and legal advocates, governments and community groups in helping explain important insurance-related issues.

In creating Understand Insurance, ICA consulted widely with consumer groups, consumer legal services, disability advocates, regulators and government agencies to help make the website as accessible and consumer friendly as possible.

The lack of adequate insurance was the focus of the national media launch campaign for Understand Insurance, held at the Museum of Contemporary Art in Sydney. This allowed for discussions on key issues and findings from consumer research, based on bespoke Quantum research of more than 1000 consumers for the initiative.

The national survey findings revealed far too many

COMMITTED TO CONSUMERS

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connect consumers with insurers while delivering record results and passing some impressive milestones. It represents the general insurance industry’s commitment to providing consumers with better access to information, and has exceeded industry expectations, reaching 1.14 million product category searches.

July 1 marked the first anniversary for the service, which was also when it passed more than a quarter of a million consumer enquiries. Inquiry rates doubled in the second half, with an average of 3037 category views each day.

By the end of 2013, the service had reached 480,413 inquiries, a milestone that had not been forecast until the end of its second year.

Find an Insurer’s call centre, established 18 months ago to complement the online service, also experienced rapid growth with 800 calls in a typical week. Staff responded to 40,334 calls during 2013, many of which related to more complex general insurance products.

The high online and telephone traffic levels along with the growing recognition of the service reveal Australians are taking an active interest in competitive insurance markets and their purchasing decisions.

Throughout the year the three most popular categories remained home, travel and comprehensive car insurance.

Find an Insurer’s ability to listen and respond to the needs of consumers proved a key element of its success. Notably, both online and telephone traffic data revealed that the number of daily visitors and category popularity followed seasonal trends and also peaked during times of natural disasters.

The ICA has also tracked a steady increase in consumers returning to the website multiple times since launch, which has now evened out about 24 per cent of all visitors, suggesting consumers find recurring value in the service.

Top 10 caller categories

THE MAIN REASONS CONSUMERS USE FIND AN INSURER

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Australians underestimate the value their assets, and choose their insurance policy based on price rather than the most suitable coverage. More than four in five Australians are risking their homes and other valuable assets by not having enough insurance. And a staggering 23 per cent of all homeowners and renters have no contents insurance at all.

An impressive turnout of both media and stakeholders gathered on the roof of the MCA, which was transformed into an outdoor living room overlooking the Sydney Opera House, to hear about the ICA’s ongoing commitment to improving public understanding of the value of insurance and the financial literacy of Australians.

NSW Police and Emergency Services Minister Michael Gallacher gave a keynote speech, talking about the importance of insurance in the community and tackling consumer issues.

Fiona Guthrie, Executive Director of Financial Counselling Australia, welcomed the insurance industry taking the lead in helping the community to better understand insurance.

Key guests also in attendance included two of Understand Insurance’s consumer case studies, Lori Whitelaw and Tamara Mactier, who chatted with guests about their personal experiences of not having adequate insurance.

Media interest in the launch campaign generated more than 90 pieces of print, online and broadcast coverage with an estimated audience reach of more than 5.5 million. A highlight of the media coverage was unpacking a house for Channel 7’s Today Tonight, which highlighted the need to regularly review insurance policies and the risks of underinsuring the contents of a home.

In its first month, the Understand Insurance website had climbed to the top Google ranking. It complements existing consumer education programs of ICA member companies and other organisations, and is already proving to be an invaluable community resource with more than 6000 unique website views and 16,800 page views.

Understand Insurance’s social channels have been steadily building their audience reach via Twitter, Facebook and YouTube.

Understand Insurance is complemented by another ICA initiative, the Find an Insurer consumer referral service, which strengthened its position during the year as a valuable and reliable resource for Australians seeking information about general insurers and their products.

The service, which the ICA took over from the Financial Ombudsman Service in July 2012 and rebuilt, continued to

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CONTRIBUTING TO REFORM PROPOSALSThe Insurance Council’s involvement in statutory compensation schemes provided an opportunity to contribute to public debate and to promote the vital role that ICA members play in these schemes.

In February the New South Wales Government said it would reform the motor accidents compensation scheme, focusing on first party and no fault. This led to much public debate with the reforms withdrawn in May.

On July 24, following a change in the relevant Minister, the government held a stakeholder roundtable where the ICA noted in-principle support for the no-fault reforms, but refused to be drawn on the extent of potential reductions in Compulsory Third Party (CTP) prices.

The ICA remained open to the prospect of reforms to ensure the scheme was sustainable and affordable, and believed streamlining the scheme would exert downward pressure on CTP prices, but there was no guarantee on the extent to which premiums may go down. The NSW Government appointed John Della Bosca and John Walsh AM as special advisers to the CTP steering committee in 2013. Both men are highly regarded by the general insurance industry and experienced in general insurance, accident compensation, disability services and injury management.

In November, the NSW Government announced a parliamentary inquiry into motor vehicle repairer and insurer relationships.

The ICA, with a significant strategic refocus on motor insurance policy matters, flagged it would seek to examine the economic impact on the structure and dynamics of the motor vehicle repair industry; technical advances in motor vehicle design and materials that are affecting the skills and resources for repairers; and the benefits of the industry’s national Motor Vehicle Insurance and Repair Industry Code of Conduct.

Also, it would seek to highlight the commitment of insurers to safe motor vehicle repairs, including the mandatory requirement under the General Insurance Code of Practice to accept responsibility for the quality of work and materials where the insurer has selected and directly authorised a repairer.

The ICA worked closely with the Financial Ombudsman Service (FOS) in 2013, contributing to the FOS Independent Review and the FOS Fee Review. The ICA believes open dialogue between FOS and the general insurance industry is essential to ensure that FOS continues to provide the most effective dispute resolution service for consumers and insurers. The ICA also supported workers’ compensation insurers and scheme agents in various jurisdictions, and continued its representation on the NSW Minister for Fair Trading’s Home Building and Motor Vehicle Industry advisory committees. The ICA maintained ongoing monitoring of relevant developments with the National Disability Insurance Scheme and National Injury Insurance Scheme.

Above: NSW’s Acting Minister for Finance and Services Andrew Constance speaks at the Compulsory Third Party (CTP) roundtable (Newspix)

RESILIENCE POLICIES PROTECT VULNERABLE COMMUNITIESDespite causing tens of billions of dollars in damage and insurance losses of more than $8.9 billion over the past three years, catastrophes have helped emphasise the importance of policies designed to protect vulnerable towns and communities at risk.

They have also demonstrated the need for Australia’s built environment to be less brittle in the face of natural disasters such as storms, cyclones, floods and bushfires.

Underscoring this point, the Productivity Commission’s report Barriers to Effective Climate Change Adaptation, released in March, said insurance played a critical role in setting a price relative to risk, giving households and

businesses incentives to change their behaviour. It found governments should only allow development in areas that were well documented as flood prone when appropriate disaster-mitigation infrastructure and strategies were in place.

Following the report, the Federal Government acknowledged that “improving resilience ... would deliver future benefits”

Above: An example of flood risks at an individual address level based on available government flood mappingInset: Measuring the ability, at an address level, for buildings to resist extreme weather events based upon their design, construction and materials used

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report also recommended an awareness program that focuses on maintenance issues, and called for a study into water ingress from wind-driven rain, which was identified as a key source of strata claims.

The ICA continues to encourage federal, state and local governments to work together to identify and fund appropriate mitigation projects alongside other possible measures such as improvements to land use planning and building codes.

The ICA is driving a number of significant resilience projects that demonstrate the relationship between hazard exposures, building vulnerability and premiums, and also support government mitigation programs by identifying affordability gains for the mitigation options being considered.

NFID forms part of a broader project to increase availability of flood insurance cover to the community. It combines all available government flood mapping into a format that is practical for underwriting of flooding risks at address level, rather than at postcode or lower resolutions.

A new ICA database coordinates access to an extensive visual resource of natural hazard mapping information, including flood, earthquake, bushfire, storm surge and cyclone exposures. It helps identify where mapping is missing, or where mitigation efforts to reduce hazards may deliver an insurance affordability outcome.

Above: Grafton residents peer over a levee holding back the Clarence River in January (AAP)

The Property Resilience and Exposure Program provides local government and the insurance industry with more robust information on the resilience of housing stock and local hazards. It enables councils to engage with the industry on affordability issues, where the primary drivers may be low-quality hazard data or a lack of information on development controls and existing buildings.

It also seeks to improve the alignment between data and hazard mapping relied upon by insurers to price risk, andinformation local governments harness for development control and town planning purposes.

The ICA will continue developing its resilience programs in 2014 with the support of the ICA Board.

and there would be significant benefits from changes to land-use planning laws that incorporated severe weather risks into planning decisions. This is in line with ICA submissions to the Productivity Commission and other inquiries.

A lack of high-quality flood data has long been an issue for insurers seeking to price risk to an individual property, and the ICA made strong improvements to its National Flood Information Database (NFID) through reaching data-sharing agreements with state and local governments.The most significant of these was a Memorandum of Understanding signed in October with the Queensland Government.

The Memorandum sets out a program intended to help address issues of insurance affordability in Queensland. It includes an exchange of data between the ICA and the Queensland Government, identification of areas lacking flood mapping data, consultation with the ICA on future mitigation planning, and joint research and development into new and better information to help assess extreme weather vulnerability. This significant step will help reduce much of the uncertainty in assessing risk and calculating insurance premiums for households and businesses.

In Victoria, the state government took steps to maintain and improve current mitigation infrastructure, moving to address a key recommendation of the Environment and Natural Resources Committee inquiry to develop a clear

structure for managing and maintaining levees. The ICA called for more funds to be allocated to be spent through the Department of Environment and Primary Industries on modernising Victoria’s approach to floodplain mapping, as a prelude to targeted support for identified at-risk communities where mitigation can be shown to be effective.

A key issue handled by the ICA related to the perceived high price of building insurance for strata-titled residential and holiday-let buildings in North Queensland. Despite the Australian Government Actuary concluding in late 2012 that prices for strata insurance had returned to a technical pricing level after many years of underpricing and that the market remained competitive, the insurance sector has faced extensive criticism.

The ICA commissioned an independent study from the Cy-clone Testing Centre at James Cook University (JCU) that examined the vulnerability of strata buildings in the region to extreme weather. The JCU report recommended strata properties undergo regular engineering inspections to ensure they are resistant to future events and to improve owners’ and insurers’ understanding of the buildings’ potential performance during cyclones and storms.

Undertaking a specialist engineering inspection would help owners and managers identify and address vulnerabilities that may exist, and may also demonstrate to strata insurers that a building may be low risk. The JCU

Above: The ICA’s Building Resilience Rating Tool shows how different elements of a building are resilient to nominated extreme weather events – high resilience values mean the element is very resilient, and low values mean the element will be prone to damage or replacement

HighResilience

LowResilience

More than 80 per cent of strata claims investigated by JCU found damage from water ingress as a result of wind-driven rain

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The New Year had hardly started when Australia faced its first catastrophe – devastating bushfires in Tasmania that became internationally infamous after publication of pictures of a family sheltering under a jetty at Dunalley.

Before the end of January, the nation had experienced four catastrophes across three states, with communities and families battling fires, floods and storm damage.

What became known as the Angry Summer started in late spring 2012, with a pool of hot air sitting over central Australia generating a series of heatwaves. This resulted in 123 weather records being broken over three months, including the hottest day ever recorded for Australia as a whole, the hottest January on record, the hottest summer average on record, and a record seven consecutive days in which the whole continent averaged above 39C.

The year also ended with fire − the Insurance Council of Australia declared its fifth and final catastrophe after bushfires ravaged New South Wales communities before the start of the traditional bushfire season.

Bushfires started affecting south-eastern Australia in November 2012, but a heatwave that struck Tasmania on January 3-4 generated extremely dangerous conditions, with several large bushfires, already burning out of control in the region, intensifying.

By January 4, Hobart had reached 41.8C, its highest temperature since records began in 1882. More than 40 fires were burning across the state and the worst- affected areas were the Tasman and Forestier peninsulas, where 202 properties were destroyed.

On January 5, the ICA declared a catastrophe covering Forcett, Dunalley, Copping and Murdunna, and Connellys Marsh, Boomer Bay, Primrose Sands, Susans Bay, Eaglehawk Neck and Taranna. By January 8, the catastrophe declaration was extended to other bushfire-affected areas including Bicheno and Lake Repulse. ICA disaster recovery staff worked in recovery centres for several months to assist policyholders. Insurers received more than 1900 claims with insured losses of $89 million.

At the same time, insurers and emergency services were preparing for the impact of dozens of bushfires across New South Wales and Victoria amid the worst bushfire conditions since Black Saturday in 2009.

Left: A firefighter works to control a bushfire in the Blue Mountains (Newspix) Top: Smoke from the Blue Mountains bushfires envelopes Sydney (AAP) Above: A property owner looks at damage caused by a bushfire near Coonabarabran, NSW (Newspix)

On January 16 the ICA declared a catastrophe for the region around Coonabarabran and the Warrumbungle National Park in northern NSW. More than 30 properties were affected and the fires caused significant damage to rural properties including outbuildings, machinery, fencing and stock. The final insurance toll was $12 million from 1500 claims.

Less than 11 days later, ex-Tropical Cyclone Oswald started causing damage, initially in northern Queensland and later with flood waters flowing all the way into New South Wales. Storms and inundation caused moderate to severe damage, and the ICA declared a catastrophe on January 27.

Insurers initially focused on Bundaberg, where more than 1000 properties were inundated. Claims rose from an initial 6100 to a total of 89,518, with insured losses of $987 million.

The ICA’s recovery team was in the region for more than six weeks, liaising with policyholders, local and state authorities, insurers and community organisations. Several hundred policyholders attended an ICA insurance forum in Bundaberg on February 20.

THE ANGRY SUMMER

21 20 Top: Flood inundation after torrential rain following ex-tropical cyclone Oswald – taken by Canadian astronaut Chris Hadfield from the International Space Station (ISS)Bottom: A firefighter battles to control spot fires in Dunalley, Tasmania (Newspix)

Ex-Tropical Cyclone Oswald also made its presence felt in NSW. On January 29, the ICA declared a catastrophe for the Tweed and Northern Rivers regions and coastal areas from the Queensland border to the Illawarra. This followed two days of extreme weather conditions and storm damage and inundation to hundreds of properties.

Though insurers had received 8000 NSW claims, mainly from Grafton and the Tweed and Northern River regions, the scale of the damage caused by the floods was notably less than that experienced in Queensland – insured losses were $121.3 million.

The standout reason was that more flood-prone communities in NSW are protected by flood infrastructure. Constructed in the 1950s and 1960s, flood mitigation in places such as Grafton had done its job and protected many communities for several generations. Without mitigation, Grafton could easily have been as severely affected as Bundaberg.

This highlighted the importance of investing in physical mitigation measures, such as levees, dams, barrages and drainage work, where it is feasible to do so. A relatively small investment to build a levee around a mid-size town may be recouped many times over the life of the levee.

Bushfire conditions returned in the spring. After monitoring the impact of several bushfires across NSW on October 17, the ICA declared a catastrophe. Communities in the Blue Mountains bore the brunt of the bushfires, with the situation remaining uncertain for several days as fires raged and more properties potentially vulnerable to damage.

The insurance industry was quick to act with assessors on the ground as soon as it was safe to do so – 90 per cent of properties in bushfire-affected regions were assessed before the end of the month. Insured losses totalled more than $183 million, with 228 properties destroyed.

More than 300 residents and policyholders attended the ICA insurance forum held on November 12, during which site clearance, underinsurance, claims and rebuilding were discussed.

The bushfires highlighted the issue of underinsurance. Many households and businesses were significantly underinsured for building and contents due to the Blue Mountains City Council rezoning and additional rebuilding costs to meet building codes applying to properties with high bushfire risks.

The ICA believes local governments are best placed to inform ratepayers of any changes to their bushfire zonings and alert them to the impact this might have on any rebuilding costs.

Top: A resident stands at her front door surrounded by flood water in Bundaberg (AAP)Middle: Dozes of North Bundaberg homes are inundated by floodwater (AAP)Bottom: Bundaberg policyholders attend an ICA-organised commnity insurance forum to discuss recovery issues (APN)

23 22 Top: A home is left 400m from its original location after floodwaters recede in Bundaberg (Newspix) Bottom: Tammy Holmes and her grandchildren take refuge under a jetty as a bushfire hits the Tasmanian town of Dunalley (AP)

SIGNIFICANT GAINS WITH ONGOING CHALLENGES Insurers achieved several significant outcomes in regulation during the year, alongside the challenges posed by some long-running as well as new issues.

After strong advocacy by the ICA among others, communicating electronically with consumers – taken as a given in today’s digital age – was finally incorporated clearly into the Insurance Contracts Act in June with the passage of the Amendment Bill.

The ICA had also argued vigorously that applying a generic remedy to insurance contracts for alleged unfair terms would be unworkable, as well as unnecessary. A Bill that would have applied this measure lapsed with the federal election and is unlikely to be revived.

Above: Ian Laughlin, Deputy Chairman, APRA, addresses the 2013 ICA Regulatory Update in February

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The ICA undertook significant work to counter the proposal from the Australian Prudential Regulation Authority (APRA) to make publicly available all the general insurance data it receives under the Financial Services (Collection of Data) Act.

Defending the need to protect the confidentiality of commercially sensitive insurance data, the ICA secured APRA’s agreement to exclude this information from its December publication. The ICA will reiterate its argument that commercially sensitive data be excluded from public release in the second stage of discussions taking place in 2014.

Through its Anti-Discrimination Working Group, the ICA continued to help members deal with issues related to the ability of insurers to differentiate the cover they offer on the basis of age, gender and disability. Of particular concern was whether insurers have the data needed to justify their use of the insurance exemption in anti-discrimination laws, with the ICA and members working with the stakeholders including the Australian Human Rights Commission and seniors organisations to address concerns.

The ICA worked with members to develop an Australian industry response on work by the International Accounting Standards Board for a single accounting standard for insurance contracts, and provided industry input to the development of guidance by the Office of the Australian Information Commissioner on compliance with the new Australian Privacy Principles.

The ICA consolidated its position as a founding member of the Global Federation of Insurance Associations (GFIA) with CEO Rob Whelan giving a keynote presentation on insurers’ responses to flooding in Australia at a workshop held in Rome in June. The workshop focused on the exploration of disaster risk management related to earthquakes and floods.

The ICA had input into key issues raised with the Russian hosts of the 2013 G-20 Summit, and contributed to GFIA’s Natural Catastrophes, ComFrame, Systemic Risk, Market Conduct, Trade and Financial Inclusion working groups.

GFIA, formed in October 2012, was active in commenting on a broad range of issues affecting the international insurance industry with 10 working groups and 20 position papers focused on a raft of common issues.

In GFIA’s inaugural annual report, chairman Frank Swed-love wrote that the international regulation of insurance was at a key point in its evolution: “For the first time, internation-al capital standards are being discussed and the ComFrame framework for internationally active companies is taking shape. The industry must be ready to speak clearly and responsibly on these issues.”

The Regulation Policy Directorate:

Held 71 Committee and Working Group meetings

Held 13 meetings with APRA, ASIC and Treasury Made 27 public industry submissions

Above: Peter Kell, Deputy Chairman, ASIC, speaks at the 2013 Regulatory Update

In an issues-packed year, the Insurance Council built on its high-touch media engagement strategy and continued its focus on transparency and availability.

This strategy also helped underpin the activities of the organisation’s Government and Stakeholder Relations (GSR) directorate under new General Manager Richard Shields.

The Communications Directorate issued 59 ICA-badged media releases and statements and provided 345 responses to individual media inquiries on topics ranging from catastrophes, strata insurance and flood cover to statutory motor vehicle personal injury insurance and the review of the General Insurance Code of Practice.

The strong level of media engagement flowed through to a record number of print and broadcast interviews.

The ICA was interviewed more than 250 times, with Communications General Manager Campbell Fuller again serving as the key ICA spokesperson. CEO Rob Whelan, General Manager Policy Risk and Disaster Planning Karl Sullivan and Special Risks Manager Laurie Ratz also took part in interviews.

Communications advisers seeded several feature articles with long-lead media and wrote comment pieces on significant matters, most notably the issue of mitigation infrastructure. The team also fielded more than 600 media calls and emails and continued to impress journalists with the ICA’s accessibility and responsiveness.

EXTERNAL FORCES

Above: Prime Minister Tony Abbott celebrates his win in the 2013 federal election (AP)

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The ICA was mentioned or quoted in more than 10,000 media reports, with a growing proportion appearing online, reaching a wider audience than traditional media channels. This was supplemented by the ICA’s social media presence via Twitter and YouTube, and through separate media activities late in the year from the ICA’s Understand Insurance consumer financial literacy initiative.

Media engagement also included an outreach program, with media events in three capital cities enabling journalists and key industry communications executives to meet informally and improve their working relationships.

The Government and Stakeholder Relations team increased its engagement with relevant Ministers, Parliamentary Secretaries, Shadow Ministers and Members of Parliament on industry issues, and also worked closely with ICA member companies through its Government Relations Committee and other groups.

In 2013, the ICA website had 214,645 visitors

Its staff travelled to every state and territory, holding a series of meetings with politicians and advisers, and providing background briefings to incoming federal and state government ministers and MPs.

Key issues canvassed included: affordability and availability of insurance generally and strata insurance in North Queensland; the Queensland Government’s Insurance Action Plan; mitigation infrastructure and investment; the Victorian Fire Services Levy transition and proposals to remove the Emergency Services Levy in New South Wales; anti-discrimination issues; changes to NSW’s CTP scheme; Unfair Contract Terms; and progress on the ICA’s 10-point disaster action plan.

The ICA was well prepared for the change in the Federal Government late in the year, meeting ministers in November and December to discuss insurance affordability and availability in North Queensland.

The GSR directorate worked closely with the ICA’s Risk and Disaster Planning Directorate on developing a Memorandum of Understanding with the Queensland Government on the provision of flood data for use by insurers. It also provided briefings on the insurance industry’s activities during and after the Blue Mountains bushfires to NSW Government Ministers and MPs, discussing issues such as access for insurance assessors, site clearances and underinsurance.

Top left: ICA CEO Rob Whelan speaks during a press conferenceTop right: ABC Lateline’s Emma Alberici interviews ICA CEO Rob Whelan about mitigationBottom left: Campbell Fuller, General Manager Communications and Media Relations, on a Fairfax website

FSL AXED BUT TAX REFORM AGENDA REMAINS Though the insurance industry believes substantive tax reform is a must for state and federal governments, progress in 2013 saw one key tax removed and challenges remain in other jurisdictions.

State taxes and levies on insurance products remain a significant cost disincentive for households and the Insurance Council of Australia has long argued that these are unfair and inefficient: they penalise responsible property owners, serve as a disincentive to be adequately insured, and significantly add to the price the customer pays.

The key reform for the year was the axing of insurer statutory contributions to Victoria’s fire services from July 1. The Fire Services Levy (FSL) reforms mean insured property owners no longer carry the cost of providing fire services to those who have chosen not to purchase insurance. Instead, this cost is spread more fairly and transparently across the community via a council rate funding model in accordance with government-set criteria. The changes should also reduce the level of underinsurance and non-insurance in the community, which will mean fewer demands on government and community organisations following extreme events such as floods and bushfires.

In June, the five largest insurers in Victoria (Suncorp, QBE, Allianz, CGU and Insurance Manufacturers Australia) appeared at a public hearing before the Fire Services Levy Monitor, Professor Allan Fels, and provided detailed evidence about how each was handling the FSL abolition.

Though the transition to the property-based charge has been challenging, the reform has greatly benefited insurance policyholders across Victoria and resulted in almost universal falls in premiums. This has been confirmed by the FSL Monitor.

The December 2013 FSL Monitor Report says: “With six months now having elapsed since the abolition of the FSL,

insurers on the whole continue to pass on the benefit of the FSL reform to policyholders. For total premium changes for the 12 months ending December 2013: Most brands have averaged a total premium reduction of between 9 and 37 per cent in the MFB region and between 15 and 44 per cent in the CFA region, largely due to the FSL coming out of the total premium.”

At the end of the 2013, the NSW Government deferred its consideration of reform of the state’s Emergency Services Levy and appointed Professor Fels to report on Victoria’s FSL transition.

Professor Fels’ report is likely to inform any changes the NSW Government might make in coming years. However, the government has acknowledged the present system of funding, which adds more than 21 per cent to the typical household premium, is unfair because people who are uninsured or underinsured do not contribute their fair share but still receive the full protection of fire and emergency services.

In the five years to June 30, 2013, Victorian insurance customers contributed $2.65 billion to fund the fire services

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Despite these positive moves, the Queensland Government went against the trend and increased stamp duties to 9 per cent effective from August 1 (up 1.5 percentage points for household policies and 4 percentage points on motor vehicle policies).

The ICA believes abolition of all state levies and stamp duties is achievable by 2015 if state and federal governments work together on tax reform. The Henry Tax Review, Productivity Commission Report into Barriers to Effective Climate Change Adaptation and the 2009 Bushfires Royal Commission all recommended the removal of taxes on insurance products.

At the end of the year, the newly elected Federal Government announced draft terms of reference for the Financial System Inquiry (FSI) and the appointment of former Commonwealth Bank of Australia CEO and ex-Future Fund chairman David Murray to lead the inquiry.

The ICA believes the FSI provides the opportunity to examine policy measures that support access and choice in general insurance and risk management in the broader community. This includes the provision of products and instruments that satisfy the needs of the future and emerging risks.

The inquiry should review the long-term nature of general insurance markets, the growing role of technology in risk pricing, and the appropriate balance between stability and competition in general insurance markets and their impacts on insurance premiums. It could also consider the evolving international regulatory environment in general insurance and its applicability to domestic settings. Substantial submissions are due by the end of March 2014, with the FSI expected to release an interim report mid-year. The ICA will be contributing a submission to the FSI.

Top: Independent Fire Service Levy Monitor Professor Allan Fels (AAP) Middle: Financial System Inquiry Chair David Murray (AAP) Bottom: A Country Fire Authority truck attempts to contain a bushfire near Donnybrook, Victoria (Newspix)Left: CFA officer Allan Eadie tackles an out-of-control bushfire raging in Dawson, Victoria (Newspix)

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2013 EVENTSThe first official event on the calendar was the Insurance Council Regulatory Update, held at the Hilton Sydney.

The full-day seminar brought insurers together with industry experts and related professions to hear about what the year had in store for the general insurance industry from a political, regulatory and business perspective.

It provided a forum for discussion to help the 250 delegates clarify the regulatory environment in which they operate and how they can meet and turn to their advantage the regulatory landscape and affordability challenges that face the industry.

The program featured 18 speakers and panellists, with keynote and plenary thought leaders including The Hon Bernie Ripoll MP, then-Parliamentary Secretary to the Treasurer; Senator Mathias Cormann, then-Shadow Assistant Treasurer and Shadow Minister for Financial Services and Superannuation; Deloitte Access Economics Partner Professor Ian Harper; Ian Laughlin, Member, APRA; Andy Cornish, CEO Direct Insurance, Insurance Australia Group, and John Morgan, Partner, Allens.

Guests were also treated to a lunchtime speaker. Author, political commentator and former newspaper columnist George Megalogenis provided a detailed assessment of the political situation in the lead up to the 2013 federal election, triggering extensive discussions between guests about the likely election result and its implications for the general insurance sector.

The ICA Annual Dinner, which returned to the Westin Hotel on May 2, is one of the most celebrated occasions of the ICA’s event calendar. The ICA refreshed the format, replacing traditional speeches with a moderated Q&A session between ICA President Mark Milliner and CEO Rob Whelan.

The discussion explored key issues facing the industry, ranging from tax reform and flood mitigation to affordability and self-regulation.

Top: Band Jazz Nouveau entertains guests at the Annual DinnerLeft: Terese Wood and Reuben Aitchison, Suncorp, mingle at the Annual DinnerRight: Delegates at the Regulatory Update

Top to bottom: Tables at the Annual Dinner; Guests at networking drinks at the Annual Dinner;Professor Ian Harper, Partner, Deloitte Access Economics, addresses the Regulatory Update

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The session also touched on the strong progress the industry has made following what Mr Whelan described as the most intense couple of years on record for the general insurance industry.

Among the 340 guests in attendance were Deputy Speaker of the NSW Legislative Assembly The Hon Thomas George and former NSW Premier The Hon Nathan Rees. Other guests included representatives from industry groups and regulators, government agencies and state and federal government advisers.

A highlight of this year’s event was the entertainment. Comedian and presenter Kitty Flanagan acted as Master of Ceremonies and performed a stand-up comedy routine that left guests in fits of laughter. Live band Jazz Nouveau provided the music throughout the event.

The dinner was preceded by the ICA Annual General Meeting and industry networking drinks.

On August 28, the Insurance Council and its members hosted the annual Treasury Luncheon at the Hyatt Hotel Canberra.

The event provided an informal environment for ICA management and senior member representatives

to meet with more than 50 representatives from departments including Treasury, Foreign Affairs and Trade, Attorney-General’s, Health and Ageing, Industry, and Prime Minister and Cabinet.

Media receptions joined the ICA’s event calendar for the second year in a row with networking opportunities taking place in Melbourne, Sydney and Brisbane.

All three events were well attended, with several dozen reporters and editors meeting communications and media relations specialists from member companies to network, improve their professional relationships and discuss trending topics and issues.

More than 850 guests attended ICA functions in 2013

Top: Comedian Kitty Flanagan entertains guests at the Annual DinnerTop to bottom: Richard Enthoven, Managing Director, Hollard Insurance; Les Hems, Director, Tomorrow’s Agenda Research Institute, Net Balance; Fiona Guthrie, Executive Director, Financial Counselling Australia; and Robynne Quiggin, Senior Manager – Indigenous Outreach Program, ASIC participate in a panel session at the Regulatory Update. Middle: Guests at networking drinks at the Annual Dinner. Bottom: George Karagiannakis, IAG, and Andy Cornish, CEO, Direct Insurance, IAG, attend the Regulatory Update

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SUBMISSIONS

Anti-discrimination

Budgets

Motor vehicles

Lenders mortgage insurance

Insurance contracts

APRA

Centrepay system Indemnity cover healthcare

State tax reform

Floods and natural disasters

Submission to the NSW Compulsory Third Party Green Slip Insurance Scheme.

Submission to the Senate Standing Committees on Legal and Constitutional Affairs on its inquiry into the Human Rights and Anti-Discrimination Bill 2012 – Exposure Draft Legislation.

Submission to the 2013-14 Commonwealth Budget.

Submission to Commonwealth Treasury on proposals in the consultation paper “Strengthening APRA’s Crisis Management Powers”.

Submission to the Independent Review of the Centrepay system.

Submission to VIC Department of Health on the review of legislation regulating private hospitals and day procedure centres.

Submission to the Economic & Finance Committee’s inquiry into the SA taxation system.

Submission to the Senate Standing Committees on Environment and Communications on recent trends in and preparedness for extreme weather events.

Technical work remains to be done on specific matters under the reform proposals, including the defined benefits structure, the practical operation of a first party scheme, more efficient, simpler and streamlined frameworks for claims management and dispute resolution, and the premium framework and regulation for no-fault and first party schemes.

In a supplementary submission to its 21/12/12 submission, the ICA states the proposed amendments create additional regulation or unnecessary burdens for the insurance industry.

Planning would be enhanced if consideration were given to the following priorities – mitigation against natural disasters, reform of state taxation including the abolition of insurance taxes and improving insurance affordability through adjustment to Centrepay arrangements.

Treasury should take full account of the differences between individual financial services sectors and the way they interact. The general insurance sector does not require the same regulatory approach as that applied to banking.

Consideration should be given to adjusting the Centrepay system to accommodate monthly insurance premium payments to improve access to insurance for individuals and families that are on low incomes.

The ICA has concerns regarding the potential for increased claims costs and therefore premium costs, depending on the powers to be provided to the regulator following the review.

Policy makers could embrace state tax reform. The abolition of state duties on insurance is clearly achievable by 2015 given the relatively small amounts of revenue involved.

The following could assist with extreme weather preparedness and the affordability and availability of insurance: creating better buildings, requiring risk appropriate use of available land, creating an informed and risk-aware community, protecting the community, lowering exposure and encouraging personal risk mitigation.

5/04/13

Submission to Joint Forum consultation paper “Mortgage Insurance: market structure, underwriting cycle and policy implications”.

The ICA does not agree with the impression created by the paper of more regulation being necessarily better in order to forestall any adverse consequences of mortgage insurance for the overall economy. The Australian Lenders Mortgage Insurance industry has been subject to a rigorous regulatory regime enforced by a vigilant regulator.

1/05/13

Submission to WA Department of Commerce, Consumer Protection on the issue of motor vehicle regulation.

The ICA supports any initiative that will increase clarity and efficiency in the regulation governing the trade in motor vehicles and motor vehicle repair and sees value in consolidating the Motor Vehicles Dealers Act 1973 and Motor Vehicle Repairers Act 2003 for efficiency purposes.

15/11/13

Submission on APRA’s discussion paper “Confidentially of general insurance data and changes to general insurance statistical publications”.

The ICA is seriously concerned by APRA’s sweeping proposal to determine that all information provided to it is non-confidential and to make it readily available to all. APRA’s proposals are inconsistent with the approach taken by the ASX and ASIC with respect to balancing confidentiality with disclosure obligations.

23/04/13

Submission to the 2014-15 Tasmanian Budget.

The twin challenge of arresting Tasmania’s economic and social challenges while re-engineering revenue arrangements can only be met through support for fundamental tax reform. The government should abandon fire levies on insurance products, engineer a tax mix switch to replace stamp duties on insurance with replacement revenue drawn from better state taxes, and replace transaction taxes on property with a broad-based land tax.

21/10/13

Submission to Treasury’s discussion paper “Financial Industry Supervisory Levy Methodology”.

The ICA broadly supports the methodology used in the calculation of the levy but has concerns about the inequitable outcomes which can result from the current treatment of reinsurance recoveries. Treasury should ensure greater transparency exists in how the total funding is calculated by regulators and how the money is spent efficiently for the purposes for which it was raised.

1/05/13

Submission to APRA on harmonising cross-industry risk management requirements.

The ICA shares APRA’s commitment to ensuring risk management plays its part in providing protection for policyholders and strongly supports the maintenance of effective risk management practices. However, the ICA has concerns that there are many elements in CPS 220 and CPS 510 that would require the abandonment or severe modification by its members of established risk management practices for no appreciable improvement in policyholder security.

10/07/13

31/01/13

31/01/13

31/01/13

15/02/13 21/05/13

Submission to APRA on GPS 100: Board Responsibility for adequacy of capital.

The ICA has concerns about the requirement that a Board ensure the regulated entity’s capital is adequate having regard to its risk profile – the satisfaction of this responsibility cannot be guaranteed in practice and is therefore inappropriate.

20/05/13

Submission on APRA’s Draft PPG 235 – Managing Data Risk.

The ICA endorses the overall approach taken in the draft PPG, which sets out a highly developed and sophisticated best practice model for data management, but it is concerned this may be overly prescriptive and too ambitious in raising issues that go beyond data management.

3/04/13

Submission to Stage One of the Reserve Bank of New Zealand’s review of bank capital adequacy arrangements for housing loans.

Submission to the inquiry by the Senate Economics Legislation Committee into the Insurance Contracts Amendments Bill 2013.

The Basel correlation factor of 15 per cent might be appropriate for the overall NZ housing portfolios but the correlation for HLVR loans should be set higher given differences between the responses to economic stress of HLVR borrowers and LVR borrowers.

The ICA strongly supports the Bill and appreciates the collaborative approach taken by consumer advocates and Treasury. The Bill should be passed as soon as possible so that consumers and the industry can have the advantage of reforms.

17/04/13

19/04/13

Submission to Treasury’s discussion paper “Changes to Disclosure Requirements under the National Consumer Protection Act 2009”.

An information statement for Lender’s Mortgage Insurance is a better option to promote understanding of LMI than an additional statement in the loan contract, which could be easily overlooked.

13/05/13

Submission to the International Accounting Standards Board’s Exposure Draft on Accounting Standards for Insurance Contracts.

The ICA supports the positive elements in the Exposure Draft but continues to have serious reservations about a number of proposed requirements, including some that will introduce more volatility into the reported results of many general insurers.

25/10/13

Submission to Treasury on Key Facts Sheets (KFS): Home Building and Home Contents Policies under the Insurance Contracts Regulations.

Landlord policies, strata policies, bundled policies and the provision of a single KFS could benefit from clarification. Also, the two KFS templates provided in the current regulation are of low quality and unsuitable for reproduction, and include some inconsistencies and errors.

2/12/13

18/01/13

14/01/13

Submission commenting on the Exposure Draft of the Insurance Contracts Amendments (Unfair Terms) Bill 2013 (UCT Exposure Draft).

The ICA cannot support the introduction of the UCT Exposure Draft in its current, seriously flawed form.4/06/13

Submission to APRA’s Response to Submissions on Supervision of Conglomerate Groups.

APRA should be mindful of the impact of additional regulation on the international competitiveness of Australian insurers and not put Australia “ahead of the pack” on regulatory matters. 8/03/13

Submission to APRA’s discussion paper “Reinsurance Counterparty Data Collection for General Insurers”.

The two draft reporting forms on reinsurance counterparty data have general industry endorsement, with the ICA setting out several suggestions to improve the forms and comments on related issues. 14/08/13

Financial industry levy

Submission to ICANN’s New gTLD Board Committee on safeguards applicable to broad categories of new gTLD (generic top level domains) strings under the GAC Beijing Communique.

While the ICA recognises the importance of gTLD names and broadly supports the appropriate expansion of these to encourage competition and provide choice to consumers, it has concerns that the inappropriate registering of some sensitive gTLDs could harm the public interest and lead to members being put at an unfair competitive advantage.

14/05/13

Submission on the Proposed Financial Industry Levies for 2013-14.

Re-statement of submission provided to Treasury on the discussion paper “Financial Industry Supervisory Levy Methodology” (1/05/13). The ICA looks forward to the resolution of the inequitable treatment of reinsurance recoveries in the levy methodology and greater transparency in how the total funding is calculated by regulators, with the money spent efficiently and offers its continued support for these issues to be addressed in time for the 2014-2015 levy process.

13/06/13

Domains

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Dispute resolution

Privacy

Risk framework

ASIC

Commonwealth laws

Law Reform Act 1946

Debt collection

The benchmarks could be updated to reflect current practices, community awareness and technological advances and published on the websites of Treasury and the Financial Ombudsman Service.

6/06/13Submission to Treasury’s public issues paper “Review of the benchmarks for industry-based customer dispute resolution schemes”.

The concepts within the APPs are not dissimilar from the principles general insurers have been following for a number of years, but some areas of the draft guidelines would benefit from revision or clarification.

20/09/13Submission to the Office of the Australian Information Commissioner (OAIC) on the first tranche of the draft guidelines for the Australian Privacy Principles (APPs).

The draft guidelines appear to discount cost as a relevant consideration of what is reason-able or practicable. Also, the guidelines should be made sufficiently flexible for entities to comply and not take an unnecessarily complex approach.

21/09/13Submission to the Office of the Australian Information Commissioner (OAIC) on the second tranche of the draft guidelines for the Australian Privacy Principles (APPs).

The ICA has no issues of concern that it wishes to raise.12/12/13Submission to the Office of the Australian Information Commissioner (OAIC) on the third tranche of the draft guidelines for the Australian Privacy Principles (APPs).

The ICA’s submission addresses questions raised by the Issues Paper including the provision of defences to adequately address the ability of general insurers to undertake surveillance activities to assess and defend a claim decision.

Commonwealth laws and legal frameworks concerning insurance do not reduce the equal recognition of people with disability and the current legislative regime is appropriate. Only through public debate will the insurance exemption be understood and accepted by the community.

11/11/13

16/12/13

Submission to the Australian Law Reform Commis-sion’s (ALRC) “Issues Paper: Serious Invasions of Privacy in the Digital Era”.

Submission to the Australian Law Reform Commis-sion’s (ALRC) Issues Paper: Equality, Capacity and Disability in Commonwealth Laws.

Submission to the Office of the Australian Infor-mation Commissioner’s (OAIC) draft guidelines for recognising external dispute resolution (EDR) schemes under S35A of the Privacy ACT.

Submission to the Attorney General’s Department on section 6 of the Law Reform Act 1946 following the NZ Bridgecorp and the Chubb v Moore cases, which considered similar issues.

Submission to the Australian Competition and Consumer Commission (ACCC) on feedback on the ACCC and Australian Securities and Invest-ments Commission’s (ASIC) revised Debt Collection Guideline for collectors and creditors.

A recognised EDR scheme is not expected to handle complaints outside its scope or terms of reference. An issue yet to be resolved is the process by which the OAIC would use its discretion to refer a complaint to an EDR scheme.

Repeal of section 6 is required to provide enduring certainty for insureds and insurers. Strong protections are available for insureds at a Federal level.

No issues of concern. The ICA welcomes the intention of the ACCC and ASIC to improve clarity on this issue, which is anticipated to benefit a wide range of stakeholders.

30/08/13

7/08/13

13/12/13

Submission to the inquiry into the Privacy Amendment (Privacy Alerts) Bill 2013.

The ICA’s submission re-states previous comments, highlighting key issues that have not been sufficiently clarified by the Bill’s Explanatory Memorandum.20/06/13

Submission to the Financial Stability Board on the Principles for an Effective Risk Appetite Framework.

Submission to ASIC on Consultation Paper 212 Licensing: Training of Financial Product Advisors.

The substance of the guidance provided in the principles document raises concerns over the contrast between the prescriptive details of Section 4 “Roles and Responsibilities” and the intention for the principles to be high level, to allow financial institutions to develop risk frameworks that are firm-specific and reflect their business model, and also allow them to adapt to the changing economic and regulatory environment in order to manage new types of risk.

All general insurance products, including consumer credit insurance (CCI) and personal sickness and accident insurance (PSA), should be classified as Tier 2 products. The ICA strongly opposes reclassification of CCI to Tier 1 and PSA remaining as a Tier 1 product because an even greater proportion of these products may be sold on a no-advice model, reducing the information to consumers in the marketplace. The costs of the proposed Tier 1 educational standards could lead to the products becoming commercially unsustainable for some insurers.

25/09/13

11/10/13

COMMITTEES AND WORKING GROUPS

Accounting Standards Working Group

ACT Workers Compensation Group

Anti-Discrimination Working Group

APRA Working Group

ASIC Working Group

Built Environment - Engineering & Construction Working Group

Built Environment Property Working Group

Code Compliance Reference Group

Code Review Working Group

Communications Committee

Consumer Credit Insurance Committee

Dust Diseases Working Party

Effective Regulation Working Group

Finance and Accounting Committee

Financial Claims Schemes Working Group

Financial Inclusion Committee

FOS Committee

Government Relations Committee

Healthcare Indemnity Working Group

Home Warranty Policy Committee

Human Resources Working Group

IAIS Working Group

Insurance Contracts Act Working Group

LMI Committee

Marine Practice Committee

National Consumer Reference Group

National Disability (NDIS and NIIS) Working Group

Motor Accidents Injury Schemes Committee (MAISC)

National Motor Insurance Committee

National Workers Compensation Committee

NSW CTP Claims Managers Group

NT Workers Compensation Sub-Committee

Pandemic Working Group

Privacy Working Group

Professional Indemnity Policy Committee

Public Liability Policy Committee

QLD CTP Managers Group

Risk Management Working Group

Rural Affairs Working Group

Sanctions Working Group

Smash Repair Sub Committee

Statutory Classes Strategy Committee

Strategic Economic and Taxation Committee

Strategic Regulatory Policy Committee

Strategic Risk and Underwriting Committee

Taxation Committee

Terrorism Working Group

Tort Reform Committee

Travel Insurance Working Group

VIC Fire Services Levy Transition Working Group

WA Workers Compensation Sub-Committee

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ICA MEMBERSAND BRANDS

Ace Insurance Limited

AIG Australia Limited

Aioi Nissay Dowa Insurance Co. Limited

Allianz Australia Insurance Limited

Ansvar Insurance Limited

AonBenfield Limited

Assetinsure Pty Limited

Auto & General Holdings Pty Limited

Avant Insurance Limited

AVEA Insurance Limited

Calliden Insurance Limited

Catholic Church Insurance Limited

Commonwealth Insurance Limited

Employers’ Mutual Limited

FM Insurance Company Limited

General Reinsurance Australia Limited

Genworth Financial Mortgage Insurance Pty Limited

Guild Insurance Limited

Guy Carpenter & Company Pty Limited

Hallmark General Insurance Company Limited

Hollard Insurance Company Pty Limited, (The)

Insurance Australia Group Limited

Insurance Manufacturers of Australia Pty Limited

JLT Towers Re Australia (Pty) Limited *

LawCover Insurance Pty Limited

Lloyd’s Australia Limited

MDA National Insurance Pty Limited

Medical Insurance Australia Pty Limited

MIPS Insurance Pty Limited

Mitsui Sumitomo Insurance Co Limited

Munich Holdings of Australasia Pty Limited

NIPPONKOA Insurance Company Limited

NTI Limited

OnePath General Insurance Pty Limited

Progressive Direct Insurance Company

QBE Insurance (Australia) Limited

RAA Insurance Limited

RAC Insurance Proprietary Limited

RACQ Insurance Limited

RACT Insurance Pty Limited

Sompo Japan Insurance Inc

Southern Cross Travel

Suncorp Group Limited

Sunderland Marine Mutual Insurance Company Limited

Swiss Reinsurance Company Limited

Territory Insurance Office

Tokio Marine & Nichido Fire Insurance Co. Limited

Virginia Surety Company Inc

Wesfarmers General Insurance Limited

Westpac General Insurance Limited

XL Insurance Global Risk

Youi Pty Limited

Zurich Financial Services Australia Limited

*joined 2013

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