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CLHIA comments regarding CCIR's Position Paper on Electronic Commerce in Insurance Products

Release Date: 07/26/2013
Staff Reference: Erica M Hiemstra

July 26, 2013

CCIR Secretariat
5160 Yonge Street
P.O. Box 85
Toronto ON
M2N 6L9

Dear Madam/Sir,

The Canadian Life and Health Insurance Association Inc. (CLHIA) is pleased to provide comments regarding Electronic Commerce in Insurance Products, the recently released position paper of the Canadian Council of Insurance Regulators (CCIR).

Established in 1894, the CLHIA is a voluntary trade association with member companies accounting for 99 percent of Canada's life and health insurance business. Our members provide Canadians with a wide range of financial security products including individual and group life insurance, health and disability insurance, annuities, RRSPs, RRIFs and pensions.

We commend CCIR for the timely and thoughtful consultation on electronic commerce. We support the view that consumers must be afforded an adequate level of information and protection regardless of how the insurance is sold. In addition, we agree with the principles-based approach taken in the paper and believe it gives life and health insurers the flexibility they need in their on-line interactions with consumers, while at the same time helping to ensure that consumer protection outcomes are met.

Our comments in the attached pages build on the comments we offered on May 3, 2012 in response to CCIR's issues paper of the same name. Specifically, we provide some clarification with respect to the life and health insurance industry's approach to a few of the consumer protection issues and offer comments regarding the electronic designation of beneficiaries and termination of insurance contracts.

CLHIA very much appreciates the opportunity to provide these further comments in support of CCIR's work in the area of electronic commerce. We are available at your convenience to provide additional information.


(Original signed by)

Frank Swedlove