Aviva insurance-Aviva Life Insurance Introduction(Aviva Canada)

About Aviva Canada Inc.
Aviva Canada Inc. (Aviva) is one of Canada’s largest property and casualty insurance groups.
Aviva wholly owns several major insurers in Canada including: Aviva Insurance Company, Pilot Insurance Company, Traders General Insurance Company, Elite Insurance Company and Scottish & York Insurance Company.
Aviva companies operate in all provinces and territories within Canada and employ approximately 3,500 people.
This response to the consultation paper is written on behalf of all companies owned by Aviva Canada Inc. and Aviva strongly supports the goal of enhancing and harmonizing best practices around disclosure in our industry.

Executive Summary
1. Aviva Canada Inc. (Aviva) is very supportive of the overall goals and direction of the Insurance Practices Review Committee (IPRC) consultation paper. We believe that where possible, the goals of the Committee should be achieved by industry associations and other stakeholders adopting agreed best practice rather than through new regulation. The risk of regulation is that flexibility to adjust to future circumstances and consumer needs becomes restricted.
Aviva also believe that consistency of application across all Canadian jurisdictions will generate benefits across the industry and for consumers.
2. All industry stakeholders have a primary responsibility to serve the needs of the consumer. Implementation should recognize however the need to avoid unnecessary costs that will ultimately be borne by the consumer. The IPRC needs to recognize the difference in both consumer need and industry business process when comparing a new policy purchase with an annual renewal purchase.
Establishing disclosure appropriate to the purchase decision, whilst minimizing unnecessary additional costs, must be the goal.
3. The nature of the required disclosure, prior to purchase at the point of sale must be simple for all advisors and their owners to implement – whilst still meeting the stated objectives. This will facilitate effective application and consistency.

Aviva Life Insurance India
Aviva Life Insurance India is a joint venture between Aviva plc – UK’s largest insurer and
Aviva Life Insurance is
steadily establishing its presence in the country and with a strong sales force of over 3000
Financial Planning Advisers (FPA’s). They have pioneered an innovative ‘need based’
sales approach to the business.
Aviva has also pioneered Bancassurance in the country through its tie-ups with leading
private and nationalised Banks in the country. Through the Bancassurance partnerships,
Aviva products are available at over 131 locations in the country.

General observations:
Should there be a difference in application between commercial insurance buyers and personal lines consumers?
The consultation paper does not make an explicit statement in this regard. Aviva believes that the recommended principles should be designed to be applicable equally to commercial buyers and personal consumers.
However, it is commonly accepted that there is greater onus, in every business sector, when dealing with the personal consumer to address potential inequities of knowledge and expertise.
The differences in role of insurance company employed customer service representatives, direct agents (offering products from a single insurance company) and insurance brokers.
The IPRC consultation paper makes little distinction identifying and describing the differences and responsibilities to the consumer of each of these groups.
The capabilities of each are different – particularly in respect to the ability search a broad range of possible markets for a given customer.
However, consumer needs and interests should be paramount in the construction of any guidelines and protocols and guide all who give insurance advice to the consumer.
Paul_Fletcher@avivacanada.com