James Daley

By James Daley

Dear Huw,

I wanted to respond to your consultation on critical illness wordings.

We think it's great that you are undertaking this work as the definitions that sit behind critical illness policies are often misunderstood and poorly worded.

Although the intentions of the latest review are right, we believe that the opportunity is not being seized to bring even greater clarity to the definitions that sit behind CI products.

Much of the model wordings remain technical - and impenetrable to the average consumer. Here's the opening to the latest stroke definition, for example: 

"Death of brain tissue due to inadequate blood supply or haemorrhage within the skull resulting in permanent neurological deficit with persisting clinical symptoms."

As the industry's leading trade body, your guidance is incredibly important. We've worked with clients before who have been reluctant to stray from the ABI's model wordings.

And by writing your documents in very technical language - with no attempt to explain these plainly to consumers - you set the wrong tone for your members.

In insurance and banking, we've seen multiple examples of model wordings from regulators and trade bodies serving as a green light to communicate poorly. The definitions are so central to a CI policy, that once you have copied and pasted in the ABI model wording, it's all too easy for internal policy writing teams to follow the same technical direction across the rest of the document.

We'd like to see the ABI pushing its members to communicate much more clearly.

Critical Illness is a complicated product even when it is explained plainly. It's a product that has built in disappointment for customers who get sick - but not sick enough. And as more providers begin to sell this product in the direct market, it's all the more important that providers go the extra mile to explain the product well to their customers

We concede that it's far from easy explaining some of these technical concepts in plain English. But we know that it's possible - we've been working with a company doing exactly that over the past few months. And we'd be more than happy to assist you as well.

I do hope there's still time to stop and reconsider these definitions before they are set in stone for your members.

All the best,