This is the FSA requirement, taken from the FSA Insurance:conduct of Business document: No less than 21 days before the expiry of the policy, an insurance intermediary must: 5.3.18 (1) if the insurance undertaking is willing to invite renewal of the policy, take reasonable steps to provide the retail customer with renewal terms in a durable medium in accordance with ¦ ICOB 5.3.21 R ; or (2) take reasonable steps to notify the retail customer if the insurance undertaking is not willing to invite renewal; or (3) notify the retail customer that the insurance intermediary no longer deals with the insurance undertaking. ¦ ICOB 5.3.18 R(2) includes circumstances where the insurance undertaking is not willing to invite renewal through the insurance intermediary in contact with the retail customer. 5.3.19 ¦ ICOB 5.3.15 R has the effect that a renewal of a non-investment insurance contract of more than one year's duration must be treated as a new sale, in order to comply with the 5.3.20 DMD. A renewal of a non-investment insurance contract which has been extended in accordance with ¦ ICOB 5.3.22 R(4), so that it is longer than one year, must also be treated as a new sale. For these contracts an insurance intermediary should provide information in accordance with the rules in ¦ ICOB 5.3.1 R to ¦ ICOB 5.3.8 R and not ¦ ICOB 5.3.15 R. The information to be provided to the retail customer in accordance with ¦ ICOB 5.3.16 R or ¦ ICOB 5.3.18 R(1) is: 5.3.21 (1) a statement of any changes to the terms of the policy; (2) an explanation of those changes, where necessary; (3) any changes to the directive-required information in ¦ ICOB 5.5.20 R (subject to ¦ ICOB 5.5.17 G to ¦ ICOB 5.5.19 R); (4) the statement of price at ¦ ICOB 5.5.14 R; (5) information about cancellation (¦ ICOB 5.3.12 R to ¦ ICOB 5.3.14 G); and (6) a prominent statement of the retail customer's right to request a new policy document. ¦ ICOB 5.3.18 R and ¦ 5.3.22 ICOB 5.3.21 R do not apply where: (1) the insurance intermediary has reason to believe that the retail customer does not wish to renew the policy through it; PAGE 13 FSA Handbook ¦ Release 052 ? March 2006 5.3.22 Section 5.3 : Provision of information to retail customers ICOB 5 : Product disclosure 5 (2) the insurance intermediary has notified the retail customer that it does not wish to act for him on renewal; (3) the retail customer has already been notified that the insurance undertaking will not invite renewal; or (4) the retail customer requests an extension to the non-investment insurance contract for a period less than that of the original non-investment insurance contract. 5.3.23 (1) Examples of situations where the insurance intermediary would have reason to believe that the retail customer does not intend to renew are travel insurance for a single trip, mortgage payment protection insurance where the mortgage has been repaid, or creditor insurance tied to the term of a loan. (2) An insurance intermediary who contacts a retail customer at least 21 days before expiry of the policy to check whether the retail customer wishes to renew, can rely on an oral statement by the retail customer that he does not wish to renew or on the retail customer's failure to respond to a request in a durable medium to contact the insurance intermediary by a specified date if he wishes to renew.
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To be honest, I think you are all probably right in that ultimate responsibility may well lie with the customer - but it is an anoying omission and without it the situation would never have arisen.
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