Nova Scotia Funeral Insurance Regulation ConsultationRelease Date: 10/28/2014 Staff Reference: Peter Goldthorpe
October 20, 2014
Service Nova Scotia
PO Box 1003
Halifax, NS B3J 2X1
Dear Mr. Hanson:
The Canadian Life and Health Insurance Association (CLHIA) is pleased to provide comment on proposals regarding the sale of funeral insurance at funeral homes.
Established in 1894, CLHIA is a voluntary trade association that represents the collective interests of its member life and health insurers which, together, account for 99% of the life and health insurance in force in Canada. Our members contribute to the financial well-being of millions of Canadians by providing a wide range of financial security products, including over $3.8 trillion of life insurance coverage. During 2011 in Nova Scotia, life and health insurers made benefit payments of $1.7 billion, or roughly $33 million a week, to policyholders and beneficiaries.
As noted in the background information included in the consultation paper, most Canadian provinces allow for the sale of funeral services insurance in funeral homes. This type of insurance can provide consumers with an economical means of funding funeral expenses. Accordingly, we commend this initiative to permit its sale in funeral homes.
Our understanding is that the proposed regulation under the Embalmers and Funeral Directors Act would apply only to funeral directors offering funeral insurance as an option to finance pre-arranged funeral expenses. More specifically, there is no intent that the proposed regulation would apply generally to the sale of life insurance which might, among other things, be recommended to customers as a means of financing funeral expenses.
These comments are in respect to those issues in the consultation that relate directly to life insurance. These issues are: record retention (Q. 1), ledgers for funeral agreements funded by the proceeds of insurance (Q. 2) and the content of purchase agreements funded by insurance (Q. 3).
The information that would be disclosed by the funeral director and the records that would kept by the funeral director are consistent with industry practices in other jurisdictions where funeral directors are permitted to offer life insurance to fund funeral expenses. Accordingly, we have no objection to the proposals.
Original signed by
Peter B. Goldthorpe
Director, Marketplace Regulation Issues