Add-on Insurance/Deferred Sales and Anti-hawking
You are no doubt aware of the legislative and regulatory changes which will have impacted the operations of those in credit and financial services from the 5th of October.
After engaging with ASIC, Zurich and legal advisors, ALI would like to advise you of their position on Deferred Sales and Anti-Hawking.
No substantial impact
In summary, there will not be any substantial change to the My Protection Plan (MPP) offer process, given the classification of their product and its role in the protection of a lifestyle that a home or property provides.
- Deferred Sales Process: MPP is a life and trauma insurance product so is NOT considered add-on Insurance and offers via a deferred sales process is not required. Therefore, there is NO change to the process.
- Anti-Hawking: MPP and the discussion on personal life risks are within the reasonable scope of the consent provided for the home loan discussion. Separate consent is NOT required to have the MPP discussion.
In a recent independent survey of 300 MPP customers, 98% believed it was reasonable of the broker to discuss personal life risks and offer MPP.
What you must ensure
To further reinforce this position, you as an authorised broker must ensure that you:
- Emphasise that offering a My Protection Plan is a service you provide to all your customers. Letting them know early on, you will have a risk discussion and offer a product during the loan process.
- Provide relevant product information to your customers before the MPP offer is made.
- Review your customer Fact Find/Needs Analysis for any personal life risk and MPP questions, to ensure consent has not been withdrawn.
- Do not discuss MPP any further if your customer has withdrawn their consent.
For any questions or concerns, please reach out to your BDM.