BIBA response to HM Treasury ‘The publication of data associated with the use of gender in the assessment of insurance risks’ consultation document

15th October 2007

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers.

BIBA represents 2,300 insurance intermediaries including 98 of the UK’s top 100 insurance intermediaries. Our members handle about half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK non-marine general insurance, of which BIBA members account for in excess of 80%. They also introduce £20 billion of premium income into London’s insurance market each year.

BIBA is pleased to have the opportunity to respond to HM Treasury‘s consultation into the publication of data associated with the use of gender in the assessment of insurance risks on behalf of its collective membership. Although not always directly involved this is a matter that is of some importance to the broking community.

BIBA has discussed the contents of the consultation paper with various stakeholders from the insurance industry, and primarily with the Association of British Insurers (ABI).

Our responses to the three options are set out as follows:

OPTION 1: Rely on existing published data sources

BIBA believes that although option 1 would be a cheap, easy route for the industry it would not properly meet the requirements of the EU Gender Directive and therefore it would not be correct for us to support this option.

OPTION 2: Mandatory record-keeping and full disclosure of all underwriting data by insurance companies

BIBA sees this option as an overly expensive gold plating of the directive and do not see the benefit to the consumer in involving the Financial Services Authority. Ultimately the £11.5 million cost would be passed on to the consumer as would the annual running costs. As you have identified competition law issues could also arise. We do not support option 2 and strongly recommend it is not implemented.

OPTION 3: An obligation on insurance companies to publish data based on guidelines issued by the Government

BIBA believes this option to be the correct solution. A high level summary should be sufficient. It meets the needs of the directive and can be achieved for a sensible cost.  We believe the ABI would be the appropriate body to enter into such an arrangement with to oversee publication of this data on behalf of the insurance company sector.

Thank you for taking the time to consider our response. If you have any further queries please do not hesitate to contact me.

Yours sincerely

Graeme Trudgill Dip CII Cert Mgmt

Manager, Technical Services

Direct Tel: 020 7397 0218

Direct Fax: 020 7626 9676

Email: trudgillg@biba.org.uk