The company should continue to investigate the sales records of all salespersons found to have been churning and against whom disciplinary action is taken. All suspected churning should then be examined with compensation, if appropriate, being given.
Actuarial comparison reports should be sent to the customer and a centralised record of all reports retained.
The company should increase its detailed review of policy applications from its present level of 20 per cent.
The company should report all fraudulent activity or misappropriation to the Garda and not just when it exceeds £5,000.
The company should continue to investigate vigorously any customer complaints.
General recommendations
The very fact that churning is not illegal is a cause for concern. This leaves the more gullible policyholder open to potential manipulation. The Minister intends to introduce measures to address this issue.
A regulatory unit should be established to administer and enforce proposed life disclosure regulations.
It is clear the problems have arisen due to the lack of disclosure in relation to policy charges and forecasts of future benefits.
Attention has been drawn to the issue of churning between companies. This should be considered in any proposed regulations on churning.
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