Access to Insurance Initiative
A global programme for sound regulatory and supervisory frameworks
Improving access to insurance for the lowincome population in Jamaica
RECOMMENDATIONS
4th July 2014
Donna Swiderek, Andrea Camargo, Sekayi Campbell, Martina WiedmaierPfister
Financial Services Commission (FSC)
Kingston, Jamaica
Jamaica is a Nascent Market
To advance inclusion it is essential to HOLISTICALLY APPROACH
THE CHALLENGES, to:
(i) Identify and address supervisory and regulatory obstacles to
offer incentives for providers to offer microinsurance products
responsibly;
(ii) encourage providers to be innovative and improve the supply of
microinsurance products that offer real value to the consumers;
(iii) promote demand,
(iv) foster trust by protecting microinsurance consumers, treating
them fairly and ensuring products offer real value
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1. Regulatory regime for responsible inclusive
insurance
• Adoption of a regulatory definition of microinsurance.
• Remove barriers for risk carriers (i.e.) reducing prudential
requirements as seen with Microinsurance Mutual Benefit
Associations in the Philippines.
• Remove access barriers for distribution channels by introducing
a new category of microinsurance intermediary distribution
channels.
• Protect the microinsurance consumer by speeding up and
simplifying processes.
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1. Regulatory regime for responsible inclusive
insurance
• Simplify microinsurance policies, but also ensure that
necessary information for consumers about rights, obligations,
applicable procedures, deadlines, complaints-handling and
dispute resolution mechanisms will be disclosed in a simple and
easy manner.
• Develop and enforce separate reporting obligations on
microinsurance business.
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2. Improving the supply of microinsurance products
with real value to consumers
• Improve the capacity of providers through training staff and
management on microinsurance best practices, proportional
training for microinsurance agents, market research and seeking
quality distribution relationship.
• Improve the offer of needed microinsurance products by
partnering with those that know the needs of the clients and
improving efficiency and innovation to reduce expenses.
• Adoption of appropriate public policies that form the basis of
public private partnerships (PPP).
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3. Improving demand and take-up
• A national financial inclusion strategy should be developed,
institutionalized and have the support of key entities.
• Integration of financial education in the financial inclusion
strategy.
• Create more mandatory products and ensure their transparency
for client awareness. (i.e.) mandatory life insurance for fishermen
through the Fishers Act that will be in place soon
• Create links to Jamaican Diaspora (i.e.) NHT overseas
contributions program, the Ministry of Foreign Affairs, El Salvador
links to their Diaspora for microinsurance.
• Promote trust through continuous contact; (i.e.) education and
awareness sessions with clients.
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4. Capacity building for FSC in regards to
microinsurance
• Pay attention to possible practices of distribution channels
that could be assimilated to abuse of a dominant position in the
market or excessive and predatory pricing.
• Leverage funding for capacity building (i.e.) FIRST Initiative;
which is part of World Bank and offers short term Technical
Assistance grants to strengthen financial sectors and build more
inclusive financial systems.
• Peer exchange- host a regional dialogue with other supervisors,
visit supervisors in other countries.
• International forums through IAIS, A2ii or Munich re to name a
few.
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5. Improving an efficient microinsurance market
through a Microinsurance Committee
• Who would be on the Committee?
o led by FSC, the committee should include providers,
distribution channels, government, regulators and
supervisor, consumer protection associations, etc.
• Consultation on MI regulatory reforms and creation of market
conduct initiatives.
• Identify MI capacity issues within Jamaica and how to fill them.
• Research and help establish a long term business case for MI
to assist with industry buy in.
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5. Improving an efficient microinsurance market
through the Microinsurance Committee
• Demand: Cooperatively deepen the understanding of the
demand for microinsurance by the target population
• Supply: Through consultations identify and facilitate steps to
improve the microinsurance supply landscape
• Establish a monitoring and evaluation (M&E) framework for
microinsurance at the country level.
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6. Protect microinsurance consumers effectively
• FSC should map any exception regimes in order to be able to
measure the risk that these providers pose for financial stability
and consumer protection.
• Institutionalise a national strategy of financial education as
part of the institutionalisation of the financial inclusion strategy.
• Ensure that consumers receive transparent, complete and
timely information about the products they purchase (marketing
materials and contractual documents).
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6. Protect microinsurance consumers effectively
• FSC should ensure that consumers are aware of the existence
and conditions of group insurance policies.
• Distribution channels and/or microinsurance intermediaries
disclose all the relevant information fully, in a transparent and
timely manner, and treat microinsurance consumers fairly.
• Insurers should adopt better practices in order to promote trust
on microinsurance market.
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6. Protect microinsurance consumers effectively
• Through regulation the FSC must clarify requirements for
internal complaints-handling mechanisms in insurance
ensuring that they are accessible and affordable.
• FSC must ensure that dispute resolution mechanisms will be
accessible and affordable for the low-income population.
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Thank you!
www.access-to-insurance.org
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